U.S. ENVIRONMENTAL PROTECTION AGENCY 

## ft

# ~EPA PRElVIANUFACTURE NOTICE Form Approved OJviB. No. 2070-0012. Approval Expires 10-31-96. 

### AGENCY USE ONLY Date of rece1pt

ES 

## 03 NOV

## -5 M1 

## 6: 07 Company 

## Sanitized**Llll~l** Ul\.- lVLllJ IIUIJJV\..1 UJ**pace~** in the Premanufacture Notice 

## ) RUCTIONS You must provide all infonnation requested in this form to the extent that it is known to orreasonably ascertainable by you. Make reasonable estimates ifyou do not have actual data. Before you complete this form. you should read the "Instructions Manual for Premanufacture Notification" (the Instructions Manual is available from the Toxic Substances Control Act (TSCA) Information Serviceby calling 202-554-1404, or faxing 202-554-5603). lfa user fee has been remitted for this notice (40 CFR 700.45), indicate in the boxes above the TS-user fee identification number you have generated. Remember. your user fee ID number must also appear on your corresponding fee remittance, which is sent to EPA, HQ Accounting Operations Branch (PM-226). P 0. 360399M, Pittsburgh. PA 15251-6399. Attn. TSCA User fee.

Part 1- GENERAL INFORMATION You must provtde the currently correct Chemical Abstracts (CA) !'-:arne ofthe new chenlicaJ substance. n·en 1f you claim the identity as confident..ia1. You may authorize another person to submit chemical identity information for you. but your submission will not be complete and the review will not begm until EPA receives this information. A letter in support ofyour submission should reference your TS user fee identification number. You must submit an original and two copies ofthis notice including all test data Ifyou cl3imed**~ny** information ;15 confidenti;1l. a single**s~nitized** copy must also be submitted.
Pan II- HUMAN EXPOSURE AND ENVIRONMENTALRELEASE If!.here are seYeral manufJcture. processing. or use operations to be described in Part II, sections A and Bofthis notice. reproduce Lhe sections as needed. Part III- LIST OFATTAClll\lENTS Altach additional sheets ifthere is not enough space to answer a question fully. Label each continuation sheet "·ith the corresponding section heading. In Part III, list these attachments, any test data or other data and any optional information included in the notice.

OPTIONAL INFORMATION You may include any information that you want EPA to consider in evaluating the new substance. On page II ofthis form space has been provided for you to described pollution prevention and recycling information you may have regarding the new substance. So-called "binding" boxes are included throughout this form for you to indicate your willingness to be bound to certain staterr.ents you make in thjs section, such as use, production volume, protective equipment
. Ths option is intended to reduce delays that routinely accompany the development ofconsent orders or Significant New Use Rules. Except in the case ofexemption applications (such as TMEA, LYE, LOREX) where certain information provided in such notification is binding on the submitter when the Agency approves the exemption application. checking a binding box in this notice does not by itselfprohibit the submitter from later deviating from the information (except chemical identity) reported in the form
CONFIDENTIALITY CLAIMS You may claim any information in Lhis notke as confidential To assert aclaim on the form. mark (X) the confidential box next to the information U1at you claim as confidentiaL To assert aclaim in an attachment. circle or bracket the informalion you claim as confidential. Jf you claiminformation in lhe notices as confidential you must also provide a sanitized version ofthe notice. (including attactunents). For additional instructions on claiming information as confidential. read the 1nstructions Manual.**~1ark** (x) ifany information in this notice is claimed as confidentiaL

EPA FORM 7710-25 (Rev. 5-95) TEST DATA AND OTHER DATA You are required to submit all test data in your possession or control and to provide a description of all other data known to or reasonably ascertainable by you. ifthese data are related to the health and environmental effects on the manufacture. processing, distribution in commerce, use, or disposal ofthe new chemical substance. Standard literature CJtations may be submitted for data in the open scientific literature. Complete test data (written in Enelish), not sununaries of data, must be submitted ifthey do not appear in the open literature. You should clearly identify whether test data is on the substance or on an analog. Also, the chemical composition ofthe tested material should be characterized. Following are examples oftest data and other data. Data should be submitted according to the requirements of §720.50 ofthe Premanufacture Notification Rule (40 CFR Part 720) Test Data (Check 1 Below any included in this notice) Environmental fate data**~** Yes• Health effects data**~** Yes Environmental effects data 0 Yes Physicai!Chemical Properties***~** Yes Other data**~** Yes Risk assessments [8l Structurelacti,·ity relationships[8l

Test data not in the possession or control ofthe submitterO A physical and chemical properties worksheet is located on the last page ofthis form. TYPE OFNOTICE (Check Only One)**~** PMN (Premanufacture Notice) 

# D INTERMEDIATE PMN (submitted in sequence with final product PMN) 

## D 

# D D SNUN (Significant New llse Notice)
Th1EA (Test Marketing Exemption Application)
LYE (Low Volume Exemption)@ 40 CFR 723.50(c)(!) z o 

## D LOREX (Low Release/Low Exposure Exemption) @40 CFR**723.50(c~** 

## D LYE Modification IS THIS ACONSOLIDATED PMN7 # ofchemicals (Prenotice Communication# re 

# I D D LOREX Modification
Yes 0"

Replaces previous editions ofEPA Fonn7710-25.Public reporting burden for this collection ofinformation is estimated to average II0hours per response, including time for reviewing

- instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding the burden estimate or any other aspect ofthis collection ofinformation, including suggestions for reducing this burden, to Chief, Information Policy Branch, PM-223, U.S. Environmental Protection Agency, 401 M. St., S.W., Washington, D.C. 20460; and to the Office ofManagement and Budget, Paperwork Reduction Act (2070-0012), Washington, D.C. 20503. 

### CERTIFICATION I certify that to the best ofmy knowledge and belief: l. The company named in PartI, section A, subsection 1a ofthis notice form intends to manufacture or import for a commercial purpose, other than in small quantities solely for research and development, the substance identified in Part I, Section B. 2. All information provided in this notice is complete and truthful as ofthe date ofsubmission. 3. I am submitting with this notice all test data in my possession or control and a description ofall otherdata known to or reasonably ascertainableby me as required by §720.50 ofthe Premanufacture Notification Rule.
Additional Certification Statements: Ifyou are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee certification statement that applies:**~** The Company named in PartI, Section A has remitted the fee of$2500 specified in 40CFR700.45(b), or 

# D The Company named in PartI, Section A has remitted the fee of$1000for an Intermediate PMN (defined @ 40 CFR 700.43) in accordance with 40 CFR700.45(b), or 

# D The Company named in Part I SectionA is a small business concern under40 CFR700.43 and has remitted a fee of$100 in accordance with 40 CFR 700.45(b). Ifyou are submitting a low volume exemption (LVE) application in accordance with 40CFR 723.50(c)(1) or a Low release and low exposure exemption (LoRex) application in accordance with 40 CFR723.50(c)(2), ch,eck the following certification statements: 

# D The manufacturer submitting this notice intends to manufacture orimport the new chemical substance for commercial purposes, otherthan in small quantities solely for research and development, under the terms of40 CFR 723.50. 

# D The manufacturer is familiar with the terms ofthis section and will comply with those terms; and 

# D The new chemical substance for which the notice is submitted meets all applicable exemptionconditions. 

# D Ifthis application is for an LYE in accordance with 40 CFR723.50(c)(l), the manufacturer intends to commence manufacture ofthe exempted substance for commercial purposes within 1year ofthe date ofthe expiration ofthe 30day review period. The accuracy ofthe statements you make in this notice should reflect your bestpredictionofthe anticipated facts regarding the chemical substance described herein. Any knowing and willful misinterpretation is**subie~Ho** criminal penalty pursuant to 18 USC 1001.

Signature ofagent
- (ifapplicable) Date

EPA FORM 7710-25 (Rev. 5-95) Page 2 ConfidentialIa. Person Name ofauthorized official Submitting Notice (in U.S.)

b. Agent (if applicable) Company

1669 Lake Avenue City, State, ZIP Code

Company Mailing address (number and street) City, State, ZIP Code Position Manager, Kodak Park Site Vice President

Position

Telephone Area Code Number

c. Ifyou are submitting this notice as part ofajoint submission, mark (X) this**box.----------------------~**

# • Joint Submitter (if applicable)

2. Technical Contact (in U.S.) Name ofauthorized official Company Mailing address (number and street) City, State, ZIP Code
Name ofauthorized official Mr. James R. Humphreys Company Eastman Kodak Company Mailing address (number and street) Position

Telephone Area Code
Position Section 5 Technical Contact

Health, Safety, and Environment, Bldg. 320, Kodak Park

3.

4.

5.

6. City, State, ZIP Code Rochester, New York 14652-6267 Ifyou have had a prenotice communication (PC) concerning this notice and EPA assigned a PC Number to the notice, enter ;;;th;,;,e,;:;nu:;;;m:.;;b:..:e;,;,r.
____ +

Ifyou previously submitted an exemption application for the chemical substance covered by this notice, enter the exemption number assigned by EPA. Ifyou previously submitted a PMN for this substance enterthe PMN number assigned by EPA (i.e. withdrawn orincomplete). Ifyou have submitted a notice ofBona fide intent to manufacrure or import for the chemical substance covered by this notice, enter the notice number assigned by EPA. I. Type ofNotice

- Mark (X) 

# D Manufacture Only Binding Option Mark EPA FORM 7710-25 (Rev. 5-95) Telephone

Mark (X) ifnone 

## L-99-0024 Mark(X) ifnone



## D
Page 3 Import Only Mark (X) ifnone
Binding Option Number 722-4749


## D

Both Confidential 

# • • IIIfanotherperson will submit chemical identity information for you (for either Item I or 2), mark (X) the box at the right. the and address ofthat in a sheet. I. Class I or 2 chemical substances (for definitions ofclass I and class 2 substances, the Instructions Manual) a. Class ofsubstance

- Mark (X)**~** Class I or 2 Class 2 b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistentwith TSCA Inventory listings for similar substances. substance based on

Confidential

For Class I substances a CA Index Name must beprovided. For Class 2 substances either a CA Index Name orCA Preferred Name must X beprovided, which ever is appropriate based on CA 9CI nomenclature rules and conventions).

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice: (check one).**~** Method I (CAS Inventory Expert Service- a copy ofthe Identification 

## 0 Method 2 (Other Source) report obtained from the CAS Inventory Expert Services must be submitted as an attachment to this 

### See 18 d. Molecular formula and CAS Registry Number (ifa number already exists for the substance)

CAS#

e. For a class I substance, provide a complete and correct chemical structurediagram. For a class 2 substance

- (I) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe the nature ofthe reaction orprocess. (3) Indicate the range ofcomposition and the typical composition (where appropriate). (4) Provide a correct representative orpartial chemical structure diagram, as complete as can be known, ifone can be reasonably ascertained.

attach a continuation sheet.
EPA FORM 7710-25 (Rev. 5-95) Page4 X
X



## XFor a class 2 substance- (I) List the immediate precursor substances with theirrespective CAS Registry Numbers. (2) Describe the nature ofthe reaction or process. (3) Indicate the range ofcomposition and the typical composition (where appropriate).
e. (I) List the immediate precursor substances with their respective CAS Registry Numbers Name (CAS#)



### Not applicable

e. (2) Describe the nature ofthe reaction orprocess


### Not applicable

e. (3) Indicate the range ofcomposition and the typical composition (where appropriate)


### Not applicable



# D Mark (X) this box ifyou attach a continuation sheet.

EPA FORM 7710-25 (Rev. 5-95) Page 5 Confdentiala. Indicate the number-average weight ofthe lowest molecular weight composition ofthe polymeryou intend tomanufacture. Indicate maximum weight percent oflow molecular weight species (not includingresidual monomers, reactants, or solvents) below 500 and below I,000 absolute molecular weight ofthat composition. Confidential

Describe the methods ofmeasurement orthe basis for your estimates: GPC

## 0 Other 

# 0: (Specify) __Not applicable
__ i) lowest number average molecular weight: _ Not applicable_ ii) maximum weight %below 500molecular weight: ___Not applicable_ iii) maximum weight % below I000 molecular weight: ___Not applicable_ attach a continuation sheet. You mustmake separate confidentiality claims for monomerorotherreactant identity, composition information, and residual information. Mark (X) the "Confidential"box next to any item you claim as confidential (I) Provide the specific chemical name and CAS Registry Number (ifa number exists) ofeach monomerorotherreactant used in the manufacture of the polymer. (2) Mark (X) this column ifentry in column (I) is confidential. (3) Indicate the typical weight percent ofeach monomer or otherreactant in the polymer. (4) Mark (X) the identity column ifyou want a monomeror other reactant used at two weight percent or less to be listed as part ofthe polymer description on theTSCA Chemical Substance Inventory. (5) Mark (X) this column ifentries in columns (3) and (4) are confidential. (6) Indicate the maximum weightpercent ofeach monomer or otherreactant that may be presentas a residual in the polymer as manufactured for commercial purposes. Mark this column if is confidential. Confi- Typical Not applicable %
% % % % o/o o/o

c. Please identify which method you used todevelop or obtain the specified chemical identity information reported in this notice (check one). 

# 0 Method I (CAS Inventory Expert Service- a copy ofthe identification report 

# 0 Method 2 (other source) obtained from CAS Inventory Expert Service must be submitted as as attachment this d. The currently correct Chemical Abstracts (CA) name for the polymerthat is consistent with TSCA Inventory listings for similar polymers. Not e. Provide a correct representative orpartial chemical structure diagram, as complete as can be known, ifone canbereasonably ascertained. Not applicable

attach a continuation sheet.

EPA FORM 7710-25 (Rev. 5-95) Page 6 Confi-
%
% % % % % o/o

### Part I-- GENERAL INFORMATION-- Continued Section B --CHEMICAL JUI'.N 111 r IN!'UKJViATION Continued 3. Impurities (a) Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial purpose. Provide the CAS Registry Number ifavailable. Ifthere are unidentified impurities. enter "unidentified." (b)
- Estimate the maximum weight% ofeach impurity. Ifthere are unidentified impurities, estimate their total weight%. Impurity and CAS Registry Number Maximum Confipercent dential (a) (b) Acetone [67-64-1] 0.001 o/o Methanol [67-56-1] 0.01 o/o
o/o
%
%
%
o/o 

## [ 

## ] Mark (X) this box ifyou attach a continuation sheet. 4. Synonyms- Enter any chemical synonyms for the new chemical identified in subsection I or 2. Contidential

X 

## D Mark (X) this box ifyou attach a continuation sheet. 5. Trade identification- List trade names for the new chemic;li substance identified in subsection I or 2. None 

## D Mark (X) this box ifyou attach a continuation sheet. 6. Generic chemical name - Ifyou claim chemical identify as confidential, you must provide a generic name for your substance that reveals the specific chemical identity ofthe new chemical substance to the maximum extent possible. Refer to the TSCA Chemical Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names. Substituted amino ethane sulfonic acid salt


## _0 Mark (X) this box ifyou attach a continuation sheet. 7. Byproducts- Describe any byproducts resulting from the manufacture, processing, use, or disposal ofthe new chemical substance. Provide the CAS Registry Number ifavailable.**Byp[~uct** CASR Number Conti- (2) dential Sodium hydroxide 1310-75-2



## [ J Mark (X) this box ifyou attach a continuation_sheet
EPA FORM 7710-25 (Rev 5-95) Page 7

### PartI

-- GENERAL INFORMATION

-- Continued Section C --PRODUCTION,IMPORT, AND USE INFORMATION: Mark (X) the "Confidential" box next to any item you claim as confidential. 1. Production volume-- Estimate the maximum production volume during the first 12 months ofproduction. Also estimate the maximum production volume for any consecutive 12-month period during the first three years ofproduction. Estimates should be on 100% new chemical substance basis. For a Low Volume Exemption application, ifyou choose to have yournotice reviewed at a lower production volume than 10,000 kg/yr. specify the volume and mark (x) in the binding box. Ifgranted, you are bound to this volume Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Conti- Binding (100% new chemical substance basis) (100% new chemical substance basis) dential Option Mark (x) 1200 1200 2. Use Information

-- You must make separate confidentiality claims for the description ofthe category ofuse, the percent ofproduction volume devoted to each category, the formulation of the new substance, and otheruse information. Mark (X) the "Confidential" Box next to any item you claim as confidential. a. (I)

-- Describe each intended category ofuse ofthe new chemical substance by function and application
.. (2)

-- Mark (X) this column ifentry column (I) is confidential business information (CBI). (3) -- Indicate your willingness to have the information provided in column (I) binding. (4)

-- Estimate the percent oftotal production for the first three years devoted to each category ofuse. (5)

-- Mark (X) this column ifentry in column (4) is confidential business information (CBI). (6)

-- Estimate the percent ofthe new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for commercial purposes at sites under your control associated with each category ofuse. (7)

-- Mark (X) this column ifentry in column (6) is confidential business information (CBI). (8)

-- Indicate %ofproduct volume expected for the listed "use" sectors. Mark more than one box ifappropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9)

-- Mark (X) this column ifentrv(ies) in column (8) is (are) confidential business infotmation (CBI). Category ofuse (I) CBI Binding Produc- CBI %in CBI % ofsubstance expected per use CBI Option tion o/o Form- (8) (by function and application i.e. a dispersive dye**~lark** (x) ulation Site- Con-* Indus- Com- Binding for finishino. polyester fibers) (2) (3) (4) (5) (6) (7) limited sumer trial mercia! Option (9) X 100% <2% o/o 100%

% %
% %
% %
% %
% % * Ifyou have identified a "consumer" use, please provide on a continuation sheet a detailed description ofthe use(s) ofthis chemical substance in consumer products.

In addition include estimates ofthe concentration ofthe new chemical substance as expected in consumer products and describe the chemical reactions by which this substance loses its identity in the consumer product. 

# D Mark (X)this box ifyou attach a continuation sheet. b. Generic Ifyou claim any category ofuse description in subsection 2a as confidential, enter a generic description ofthat category. Read the use Instructions Manual for examples ofgeneric use descriptions. description Contained use in digital and imaging products 

# D Mark (X) this box ifyou attach a continuation sheet. 3. Hazard Information-- Include in the notice a copy ofreasonable facsimile ofany hazard warning statement. labeL material safety data sheet, or other Binding

information which will be provided to any person who is reasonably likely to be exposed to this substance regarding protective equipment or practices Option Mark (xl for the safe handing, transport, use, or disposal ofthe new substance. List in part Ill hazard information you include. 

## [2J Mark (X) this box ifyou attach hazard information. 

# Se.

## e.. ?a.C\e

## ~ 

# 1..**~-** 

## "L 

# 'l "' EPA FORM 7710-25 (Rev. 5-95) Page 8

### Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER Mark (X) box nextto any item you claim as Complete section A for each type ofmanufacture, processing, oruse operation involving the new chemical substance at industrial sites you control. Importers do not have to complete this section for operations outside the U.S.; however, you may still have reporting requirements if there are further industrial after i You must describe these
. See instructions manual ofthe site at which the will occur. dential Kodak Park Site address (number and street) 1669 Lake Avenue City, County, State, ZIP code Rochester, Monroe, New York 14652 Ifthe same operation will occur at more than one site, enterthe number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates or operations, include all the information requested in this section for those sites as attachments.

b.

I. Batch

2. Continuous attach a continuation sheet.

Maximum kg/batch (IOO'k new chemical 1 Hours/batch substance) I 

### 300 I Maximum kg/day (100% new chemical 1 Hours/day substance) 1 

### 72

d. Process description Mark (X) to indicate your willingness to have yourprocess description binding. Use

1 Batches/year I

: Days/year 4 

## X (I) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). (2) Provide the identity , the approximate weight (by kg/day or kg/batch on a I00% new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and ofall products. recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch.). (3) Identify by number the points ofrelease, including small orintermittent releases, to the environment ofthe new chemical substance.

attach a continuation sheet. 

### See 20-21
EPA FORM 7710-25 (Rev. 5-95) Page 9

### Part 11-- HUMANEXPOSUREAND ENVIRONMENTAL RELEASE

-- Continued Section A

-- INDUSTRIAL SITES CONTROLLED BY THESUBMITTER

-- Continued 2. Occupational Exposure·· You must make separate confidentiality claims for the description ofworker activity, physical form ofthe new chemical substance, numberofworks exposed, and duration ofactivity. Mark (X) the "Confidential" box next toany itemyou claim as confidentiaL (I)-- Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) --Mark (X) this column ifentry in column (I) is confidential business information (CBI). (3) --Describe any protective equipment and engineering controls used to protect workers. (4) and (6) --Indicate your willingness to have the information provided in column (3) or (5) binding. (5) --Indicate the physical form(s) ofthe new chemical substance (e.g., solid: crystal, granule, powder, ordust) and% newchemical substance (ifpart ofa mixture) at the time ofexposure. (7) --Mark (X) this column ifentry in column (5) is confidentialbusiness information (CBI). (8) --Estimate the maximum numberofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidentialbusiness information (CBI). (I0) and (II)

-- Estimate the maximum duration ofthe activity for any worker in hours perday and days peryear. (12)

-- Mark (X) this column ifentries in columns (I0) and (II) are confidentialbusiness information (CBI). Worker activity CBI Protective Equipment/ Binding Physical fonns(s) Binding CBI #of CBI Maximum duration CBI (i.e., bag dumping, filling drums) Engineering Controls Option and% new Option Workers Hrs/day Days/yr Mark (x) substance Mark (x) Exposed (I) (2) (3) (4) (5) (6) (7) (8) (9) (10) (II) (12) Cleaning of filtering and See pages 23-27 Damp solid 2 0.5 4 collection equipment <0.1% Loading the collection See pages 23-27 Slurry 2 0.3 4 equipment <30% Loading the drying equipment See pages 23-27 Damp solid 2 1.0 4 -90% Loading the container See pages 23-27 Dry solid 2 1.0 4 100% %**~** Mark (X) this box ifyou attach a continuation sheet. 

### See pages 23-27 3. Environmental Release and Disposal

-- You must make separate confidentiality claims for the release number and the amount ofthe new chemical substance released and otherrelease and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (I) --Enterthe numberofeach release point identified in the process description, part II, section A, subsection Id(3). (2) --Estimatethe amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day orkg/batch). (3) --Mark (X) this column ifentries in columns (I) and (2) are confidential business information (CBI). (4) --Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land orincineration, POTW, orother (specify)) to which the new substance will be released from that release point. (5) --a. Describe control technology, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment. For releases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRAhazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary ortertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day). (6) --Mark (X) this column ifentries in columns (4) and (5) are confidential business information (CBI). (7) --Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publicly OwnedTreatmentWorks). Mark (X) ifthe POTWname or NPDES #is confidential business information (CBI). Release Amount ofnew substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI Number released release

(I) (2a) (2b) e g. stack au I Binding (3) (4) (5a) I Mark (X) (5b) (6) I 1 None <2 incineration container Incineration (>99.99% ORE) I None I kg/batch I I 2 None <0.5 recovery tank Solvent Recovery/Incineration (>99.99% ORE) I None I kg/batch I I 3 None <1.0 industrial sewer Biological treatment/Incineration (>99.9% ORE) I <0.5 kg/day I kg/batch I I I I I I I I I I (7) Mark (X) the 

# 0 POTW provide name(s) below: CBI

### ~Navigable 

# 0 Other- Specify provide NPDES # CBI

- destination(s) of waterway releases to water. NY-000-1643

### ~ Mark (X) this box ifyou attach a continuation sheet. 

### See pages 15 and43

EPA FORM 7710-25 (Rev. 5-95) Page 10

### Part 11-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE Section A

-- INDUSTRIAL SITES CONTROLLED BY THESUBMITTER Mark (X) the "Confidential" box next to any itemyou claim as confidential Complete section A for each type ofmanufacture, processing, oruse operation involving the new chemical substance at industrial sites you control. Importers do not have to complete this section for operations outside the U.S.; however, you may still havereporting requirements if there are further industrial · after You must describe these ons. See instructions manual ofthe site at which the will occur. dential Name Kodak Park Site address (number and street) 1669 Lake Avenue City, County, State, ZIP code Rochester, Monroe, New York 14652 Ifthe same operation will occur at more than one site, enterthe number ofsites. Identify the additional sites on a continuation sheet, and ifany ofthe sites have significantly different production rates oroperations, include all the information requested in this section for those sites as attachments. Mark (X) this box if b. Type-- Mark (X)

I. Batch

2. Continuous attach a continuation sheet.

Maximum kg/batch (100% new chemical 1 Hours/batch substance) r 14 I Maximum kg/day (100% new chemical : Hours/day substance) 1 120

d. Process description Mark (X) to indicate your willingness to have your process description binding. Use

1 Batches/year 

### 86 : Days/year 

## X (I) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a I00% new chemical substance basis), and entry point ofall starting materials and feedstocks (including reactants, solvents. catalysts, etc.), and ofall products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily or perbatch.). (3) Identify by numberthe points ofrelease, including small or intermittent releases, to the environment ofthe new chemical substance.

attach a continuation sheet. 

### See 22
EPA FORM 7710-25 (Rev. 5-95) Page II

### Part 11-- HUMANEXPOSUREAND ENVIRONMENTALRELEASE-- Continued Section A

-- INDUSTRIAL SITES CONTROLLED BY THESUBMITTER

-- Continued 2. OccupationalExposure-- You must make separate confidentiality claims for the description ofworker activity, physical form ofthe new chemical substance, number ofworks exposed, and duration ofactivity. Mark (X) the "Confidential"box next to any item you claim as confidential. (I)-- Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the substance. (2) --Mark (X) this column ifentry in column (1) is confidentialbusiness information (CBI). (3) --Describe any protective equipment and engineering controls used to protect workers. (4) and (6) --Indicateyour willingness to have the information provided in column (3) or (5) binding. (5) --Indicate the physical form(s) ofthe new chemical substance (e.g., solid: crystal, granule, powder, or dust) and% new chemical substance (ifpart ofa mixture) at the time ofexposure. (7) --Mark (X) this column ifentry in column (5) is confidentialbusiness information (CBI). (8) --Estimatethe maximum number ofworkers involved in each activity for all sites combined. (9) --Mark (X) this column ifentry in column (8) is confidential business information (CBI). (10) and (II)-- Estimate the maximum duration ofthe activity for any worker in hours per day and days per year. (12) -·Mark (X) this column ifentries in columns (10) and (11) are confidential business information (CBI). Worker activity CBI Protective Equipment/ Binding Physical forms(s) Binding CBI #of CBI Maximum duration CBI (i.e., bag dumping, filling drums) Engineering Controls Option and% new Option Workers Hrs/day Days/yr Mark (x) substance Mark (x) Exposed (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (II) (12) Weighing of the chemical See pages 23-27 Dry solid 6 0.1 20 100% Loading the milling vessel See pages 23-27 Dry solid 6 0.1 20 100% Cleaning of filtration equipment See pages 23-27 Damp solid 6 0.1 20 <5% Loading the ink processing See pages 23-27 Dispersion 6 0.1 20 vessel <8% Loading the containers See pages 23-27 Dispersion 6 1 20 <2%

### ~ Mark (X) this box ifyou attach a continuation sheet. 

### See]!_ages 23-27 3. Environmental Release and Disposal

-- You must make separate confidentiality claims for the release number and the amount ofthe new chemical substance released and otherrelease and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential. (I) --Enterthe number ofeach release point identified in the process description, part II, section A, subsection Id(3). (2) --Estimate the amount ofthe new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch). (3) --Mark (X) this column ifentries in columns (I) and (2) are confidential business information (CBI). (4) --Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or other (specify)) to which the new substance will be released from thatrelease point. (5) --a. Describe control technology, ifany, and control efficiency that will be used to limit the release ofthe new substance to the environment. Forreleases disposed ofon land, characterize the disposal method and state whether it is approved for disposal ofRCRA hazardous waste. On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to secondary ortertiary on-site treatment. b. Estimate the amountreleased to the environment after control technology (in kg/day). (6) --Mark (X) this column ifentries in columns (4) and (5) are confidentialbusiness information (CBI). (7) --Identify the destination(s) ofreleases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct discharges or NPDES numbers ofthe POTW (Publicly Owned TreatmentWorks). Mark (X) ifthe POTW name or NPDES #is confidential business information (CBI). Release Amount ofnew substance CBI Media of Control technology and efficiency (you may wish to optionally attach efficiency data) CBI Number released re]ease

(I) (2a) (2b) eg. st:w.:k mr I Binding (3) (4) (Sa) I Mark (X) (5b) (6) I 1 None <0.05 incineration container Incineration (>99.99% ORE) I None I kg/batch I I I I I I I I I I I I I I I I I I (7) Mark (X) the 

# 0 POTW provide name(s) below: CBI 

# 0 Navigable 

# 0 Other

- Specify provide NPDES # CBI r---- destination(s) of waterway releases to water.

### ~ Mark (X) this box ifyou attach a continuation sheet. 

### See page 15

EPA FORM 7710-25 (Rev. 5-95) Page 12

### Part 11-- HUMANEXPOSURE AND ENVIRONMENTAL RELEASE

-- Continued Section B

-- INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section B for typical processing or use operations involving the new chemical substance at sites you donot control. Importers do not have to complete this section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual. Complete a separate section Bfor each type of processing, or use operation involving the new chemical substance. Ifthe same operation is performed at more than one site describe the typical operation common to these sites. Identify additional sites on a continuation sheet. 1. OperationDescription-- To claim information in this section as confidential, circle orbracket the specific information that you claim as confidential. (I)-- Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) --Provide the identity, the approximate weight (by kg/day or kg/batch, on an I00% new chemical substance basis), and entry point ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaningchemicals (note frequency ifnot used daily or per batch). (3)

-- Identify by number the points ofrelease, including small or intermittentreleases, to the environment ofthe new chemical substance. (4) Please enter the# ofsites (rememberto identify the locations of these sites on a continuation sheet): 

### Seepage 19 i 

# ,; J
..

# r.)**~ ·~**  

## f1 ' ..

# ,,.. ,.\-\ 1



### ... • I ( l •, . l 

# .' ' I I i ; r ' ! : ,, ; .' • . , , I, • " #ofsites 

### ;.**.~** 

### ·,.**~** 

### • r 

### s(
..i**~J ~** **.~,** 'f I ' I j ' I ' i ',.< 

### Inkjet Renew 17642 N. 251 h 

### Ave. 

### / 

### / Phoenix, Arizona 85023 Water [7732-18-5] 

### B"" Cleaning 

# - Drums**~** 1 II"" 

## 1/ A**~t** 

# / 

# / 500-ml bottles 

# / 

# D Mark (X) this box ifyou attach a continuation sheet. 2. WorkerExposure/Environmental Release (I)-- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described. (2) --Estimate the numberofworkers exposed for all sites combined. (4) --Estimate the typical duration ofexposure per worker in (a) hours per day and (b) days per year. (6) --Describe physical form ofexposure and %new chemical substance (ifin mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7) --Estimatethe percent ofthe new substance as formulated when packaged or used as a final product. (9) --Fromthe process diagram above, enter the number ofeach release point. Complete 9-13 for each release point identified. (10) --Estimatethe amount ofthe new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch). (12) --Describemedia ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site oroff-site land or incineration, POTW, or other (specify) and control technology, ifany, that will be used to limit the release ofthe new substance to the environment. (14)

-- Identify byproducts which may result from the operation.

(3), (5), (8), (II), (13) and (15)

-- Mark (X) this column ifany ofthe proceeding entries are confidential business information (CBI). Letter #of CBI Duration CBI Protective Equip. I %in CBI Release Amount of CBI Media ofRelease CBI

of Workers of Engineering Controls/ Form- Number New &Control Act- Exposed Exposure Physical Form and % ulation Substance Technology ivity new substance Released (I) (2) (3) (4a) I (4b) (5) (6) (7) (8) (9) (lOa) I (lOb) (II) (12) (13) A 5 6 I 40 Dispersion (<2%) <2% 1 None : <0.001 Sewer I I I See MSDS on pages 23-27 I I kg B 5 0.1 I 40 Dispersion (<2%) <2% 1 None I <0.001 Sewer I I See MSDS on pages 23-27 : kg I I I I I I I I I I I I I I I I I I (14)

-- Byproducts: (15)

None 

# D·Mark (X) this box ifyou attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 13

### Part

### 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE-- Continued Section B --INDUSTRIAL SITES CONTROLLED BY OTHERS Complete section B for typical processing or use operations involving the newchemical substance at sites you donot control. Importers do not have to complete this section for operations outside the U.S.; however, you mustreport any processing oruse activities after import. See the Instructions Manual. Complete a separate section B foreach type of processing, oruse operation involving the new chemical substance. Ifthe same operation is performed atmore than one site describe the typical operation common tothese sites. Identify additional sites on a continuation sheet. 1. OperationDescription-- To claim information in this section as confidential, circleorbracket the specific information that you claim as confidential. (I)-- Diagram the majorunit operation steps and chemical conversions, including interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) --Providethe identity, the approximate weight (by kg/day orkg/batch, on an 100% new chemical substance basis), and entrypoint ofall feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle streams, and wastes. Include cleaning chemicals (note frequency ifnot used daily orperbatch). (3) --Identifyby numberthe points ofrelease, including small orintermittent releases, to the environment ofthe new chemical substance. (4) Pleaseenter the#ofsites (rememberto identify the locations of these sites on a continuation sheet): 

### See page 19 

# CONFIDENTIAL 1 #ofsites



# D Mark (X) this box ifyou attach a continuation sheet. 2. WorkerExposure/Environmental Release (I)-- From the diagram above, provide the letterfor each worker activity. Complete 2-8 for each worker activity described. (2) --Estimatethe number ofworkers exposed for all sites combined. (4) --Estimatethe typical duration ofexposure perworkerin (a) hours per day and (b) days peryear. (6) --Describe physicalform ofexposure and o/o new chemical substance (ifin mixture), and any protective equipment and engineering controls, ifany, used to protect workers. (7) --Estimatethe percent ofthe new substance as formulated when packaged orused as a final product. (9) --From the process diagram above, enterthe number ofeach release point. Complete 9-13 for each release point identified. (I0)

-- Estimate the amount ofthe new substance released (a) directly to the environment or (b) intocontrol technology to the environment (in kg/day orkg/batch). (12)

-- Describe media ofrelease i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site oroff-site land orincineration, P01W, orother (specify) and control technology, ifany, that will be used to limit the release ofthe new substance to the environment. (14) --Identifybyproducts which may result from the operation.

(3), (5), (8), (II), (13) and (15)

-- Mark (X) this column ifany_ofthe proceedingentries are confidential business information (CBJ). Letter #of CBI Duration CBI Protective Equip. I %in CBI Release Amountof CBI Media ofRelease CBI

of Workers of Engineering Controls/ Fonn- Number New &Control Act- Exposed Exposure Physical Form and o/o ulation Substance Technology ivity new substance Released (I) (2) (3) (4a) I (4b) (5) (6) (7) (8) (9) (lOa) I (lOb) (II) (12) (13) X I X X I X X I I I I I I X I X X I I I I I I I I I I I I I I I (14)

-- Byproducts: (15)

None 

# 0 Mark (X) this box ifyou attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 14

## OPTIONAL POLLUTIONPREVENTION INFORMATION To claim information in this section as confidential circle or bracket the specific information that you claim as confidential. 

### In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce orminimize potential risks associated with activities surrounding manufacturing, processing, use and disposal ofthe PMN substance. Please include new information pertinent to po11ution prevention, including source reduction, recycling activities and saferprocesses orproducts available due to the new chemical substance. Source reduction includes the reduction in the amount ortoxicity ofchemical wastes by technological modification, process and procedure modification, productreformulation, raw materials substitution, and/or inventory control. Recycling refers to the reclamation ofuseful chemica] components from wastes that would otherwise be treated orreleased as air emissions orwater discharges, orland disposal. Descriptions ofpo11ution prevention, source reduction and recycling should emphasizepotential riskreduction subsequent to compliance with existingregulatory requirements and can be either quantitative orqualitative. The EPA is interested in the information to assess overa11 net reductions in toxicity or environmental releases and exposures, not the shifting ofrisks to otherenvironmental media ornon-environmental areas (e.g., occupational orconsumerexposure). In addition, information on the relative cost orperformance characteristics ofthe PMN substance to potential alternatives may be provided. 

### All information provided in this section will be taken into consideration duringthereview ofthis substance. See InstructionsManual and Pollution Prevention Guidance manualfor guidance and examples. Describe the expected net benefits, such as (1) an overall reduction in risk to human health or the environment; (2) a reduction in the volume manufactured; (3) a reduction in the generation ofwaste materials through recycling, source reduction orother means; (4) a reduction in potential toxicity orhuman exposure and/or environmental release; (5) an increase in product performance, a decrease in the cost ofproduction and/or improved operation efficiency ofthe new chemical substance in comparison to existing chemical substances used in similar application; or (6) the extent to which the new chemical substance may be a substitute for an existing substance that poses a greater overall risk to human health or the environment. The stoichiometry was optimized to avoid using an unnecessary excess of starting materials and reagents. For all manufacturing operations (reaction, work-up) the quantity of volatile organic solvents will be kept at a minimum. Batch size has been maximized to reduce clean up waste. Drums containing starting materials are emptied thoroughly before recycling or incineration. Methanol distillates and acetone cleaning liquors are collected and distilled for reuse. WASTE MANAGEMENT KODAK PARK, ROCHESTER, N.Y. All wastes containing the notified substance are sent to control technologies prior to release to the environment. Aqueous wastes are sent to the company's on-site wastewater treatment facility (WWTU) that is operated in compliance with state and federal regulations. Selected solvents are purified and recycled. Non-recyclable organic wastes are combusted in the company's on-site rotary kiln incinerator that is also operated in compliance with state and federal regulations. Occasionally wastes may be sent off site for treatment at an approved contract facility or for metals reclamation.



# D Mark (X) this box ifyou attach a continuation sheet. EPA FORM 7710-25 (Rev. 5-95) Page 15

## Part 

## III-- LIST OF ATTACHMENTS Attach continuation sheets for sections ofthe form and test data and other data (including physical/chemical properties and structure/activity information), and optional information after this page. Clearly identify the attachment and the section ofthe form to which it relates, ifappropriate. Numberconsecutively the pages ofthe attachments. In the column below, enter the inclusive page numbers ofeach attachment. Mark (X) the "Confidential"box next to any attachment name you claim as confidential. Read the Instructions Manual for guidance on how to claim any information in an attachment as confidential. You must include with the sanitized copy ofthe notice form a sanitized version ofany attachment in which vou claiminformation as confidential.

# Attachment name Attachment Contipage number(s) dential 1 Physical and Chemical Properties Worksheet 17 2 CAS Inventory Expert Service Name 18 3 Flow Diagram for Processing of the PMN Chemical 19 4 Manufacturing Diagram 20-21 5 Processing Diagram 22 6 Material Safety Data Sheet 23-27 7 Other Data: Estimations of Health and Environmental Fate and Effects 28-45 8 Activated Sludge Respiration Inhibition Screening Test 46-59 9 Acute Oral Toxicity Study in the Rat 60-78 10 Purity Determination 79-97 11 UltravioleWisible Light Spectroscopy 98-114 12 Analysis by Infrared Spectroscopy 115-126 13 Analysis by NMR Spectroscopy 127-140 14 Physico-Chemical Properties with Respect to Solid Flammability 141-149 15 Risk Assessment for Annex VIIC Notification 150-160



# 0 Mark (X) this box ifyou attach a continuation sheet. Enterthe attachment name and number.

EPA FORM 7710-25 (Rev. 5-95) Page 16

## PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET
To assist EPA's review ofphysical and chemical properties data, please complete the following worksheet for data you provide and include it in the notice. Identify the property measured, the page ofthe notice on which the property appears, the value ofthe property, the unit in which the property is measured (as necessary), and whether or not the property is claimed as confidential. Ifthe attachments are electronic, give the attachment number (found on page 12) at (b). Thephysical state ofthe neat substance should be provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures orformulation should be so noted(% PMN substance in_). You are not required to submit this worksheet; however, EPA strongly recommends that you do so, as it will simplify review and ensure that confidential information is properly protected. You should submit this worksheet as a supplement to your submission oftest data. This worksheet is not a substitute for submission oftest data. Property Mark (X) Page Value(c) Measured or Confif number Estimate dential provided (b) (MorE) Mark (X) (d) Physical state of neat substance

### ~ 25

## ~ (s) 

# D (I) 

# D (g) 

# D M Vapor pressure 

# D Not available 

# D @Temperature 

# oc Density/relative density 

# D Not available 

# D Solubility 

# D Not available 

# D @Temperature 

# oc Solvent Solubility in water @Temperature 

# D Not available 

# D oc Melting temperature 

# D Not available 

# D Boiling/sublimation temperature @ 

# D Not available 

# D torr pressure Spectra

### ~ 98-140 UVNis, IR, and NMR spectra

### ~ M Dissociation constant 

# D Not available 

# D Particle size distribution 

# D Not available 

# D Octanol Iwater partition coefficient 

# D Not available 

# D Henry's Law constant 

# D Not available 

# D Volatilization from water 

# D Not available 

# D Volatilization from soil 

# D Not available 

# D pH @concentration 

# D Not available 

# D Flammability

### ~ 141-149 Not highly flammable M

### ~ Explodability 

# D Not available 

# D Adsorption I coefficient 

# D Not available 

# D Other - Specify 

## rg] 79-97 Purity M 

## rg] Other- Specify 

## rg] DSC 

## rg] 160 M 

# D Mark (X) this box ifyou attach a continuation sheet. F.ntf"r tht> :ltt:lchmf'nt**n;~mp** ;:mrl nnmhf'r 

# 17

# InventoryExpertService

A division of the American Chemical Society Phone: 800-63 1-1884, 614-447-3600 (ext.2308) 

# CONFlDENTlAL

INVENTORY EXPERT SERVICE REPORT Fax: 614-+47-3747 E-mail: answers@cas.org

IES-ORDER NUMBER:

CA IN!JEX NAME

Please print the above CA Index Name on the appropriate page of your PMN. 

# D If this box is checked, CAS has made correction(s) marked in red to your IES order. Please make the same correction(s) to your PMN before submitting it to the EPA.



## JCZ

P.O. Box 33<43 Columbus, Ohio -432I0-033-4r·-

# CONFIDENTIAl

/9

# CONFIDENTIAL

1_0

# · CONFIDENTIAL**~I**

# CONFIDENTIAL

22Printed: 10/28/2003 Report Version: 1 . 000008201/F/USA Approval Date: 09/24/2002 Page: 1/1**~ffiTERIAL** SAFETY DATA SHEET 

# CONFIDENTIAl

FOR USE ONLY WITHIN**EAST~** KODAK COMPANY AND ITS SUBSIDIARIES. PRIOR APPROVAL IS REQUIRED FOR DISTRIBUTION OF THIS MSDS TO ANYONE OTHER THAN A KODAK EMPLOYEE. PHONE: THE KODAK ROCHESTER HEALTH, SAFETY AND ENVIRONMENT

- MSDS SERVICES GROUP (72-27178) 1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION Product Name: -) Product Identification

### Number:~ Manufacturer/Supplier:**EAST~** KODAK COMPANY and Subsidiaries MSDS Prepared by: MSDS Prepared by: Health, Safety and Environment Organization, Eastman Kodak Company, Rochester, NY 14652-6267. InCanada, call: (416) 766-8233. For Emergency Health, Safety & Environmental Information, call: United States: (585) 722-5151 Canada: 1-800-363-1024 Brazil: Knet 2686333, or phone number 12-332-6955 

## _____....._ KAN Number: ' l 

# - Synonym(s): I }
Molecular Formula:( \ 

# _____ .-/ Molecular Weight: 442.0 IMPORTANT NOTE: This chemical is the subject of a Low Volume Exemption.
2.**COMPOSITION/INFOR~ffiTION** ON INGREDIENTS Weight%- Component- (CAS Registry No.)

3. HAZARDS IDENTIFICATION POWDERED MATERIAL MAY FORM EXPLOSIVE DUST-AIR MIXTURES CAN DECOMPOSE AT ELEVATED TEMPERATURES THE TOXICOLOGICAL PROPERTIES OF THIS MATERIAL HAVE NOT BEEN FULLY INVESTIGATED HEALTH HAZARD EVALUATION BASED, IN PART, ON DATA FOR A STRUCTURALLY SIMILAR MATERIAL MAY CAUSE BLOOD DISORDERS BASED ON ANIMAL DATA HARMFUL IF INHALED, ABSORBED THROUGH SKIN, OR SWALLOWED CAUSES SKIN AND EYE IRRITATION CAUSES SNEEZING Eastman Kodak Hazard Ratings: R-2, S-2, F-1, C-lT
4. FIRST-AID MEASURES Inhalation: Move to fresh air. Treat symptomatically. Get medical attention if symptoms occur.Printed: 10/28/2003 Report Version: 1 . 000008201/F/USA Approval Date: 09/24/2002 Page: 2/2 MATERIAL SAFETY DATA SHEET

Eyes: Immediately flush with plenty of water for at least 15 minutes. Get medical attention. Skin: Immediately flush with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Get medical attention if symptoms occur. Wash contaminated clothing before reuse. Destroy or thoroughly clean contaminated shoes. Ingestion: Only induce vomiting at the instruction of medical personnel. Call a physician or poison control center immediately. Never give anything by mouth to an unconscious person.
5. FIRE FIGHTING MEASURES Extinguishing Media: Water spray, carbon dioxide (C02), dry chemical. Special Fire-Fighting Procedures: Wear self-contained breathing apparatus and protective clothing. Fire or excessive heat may produce hazardous decomposition products. Hazardous Combustion Products: Carbon dioxide, carbon monoxide, oxides of nitrogen, oxides of sulfur. Unusual Fire and Explosion Hazards: Powdered material may form explosive dust-air mixtures. Fire or high temperatures may cause decomposition.
6. ACCIDENTAL RELEASE MEASURES Collect up and put ln a suitable container. Avoid generation of dust. Clean surface thoroughly to remove residual contamination.
7. HANDLING AND STORAGE Personal Precautionary Measures: Avoid breathing dust. Avoid contact with eyes, skin, and clothing. Use with adequate ventilation. Wash thoroughly after handling. Prevention of Fire and Explosion: Keep away from heat. Powdered material may form explosive dust-air mixtures. Minimize dust generation and accumulation. Use with adequate ventilation. Keep away from sources of ignition. Refer to NFPA Pamphlet No. 654, "Prevention of Fire and Dust Explosions in the Chemical, Dye, Pharmaceutical, and Plastics Industries." Keep from contact with oxidizing materials. Storage: Keep container closed.
8. EXPOSURE CONTROLS/PERSONAL PROTECTION Exposure Limits: Not established. Ventilation: Good general ventilation (typically 10 air changes per hour) should be used. ventilation rates should be matched to conditions. Use process enclosures, local exhaust ventilation or other engineering controls to maintain airborne levels to an acceptable level. Transfer of the dry solid will be done using local exhaust. Respiratory Protection: If engineering controls do not maintain airborne concentrations to an acceptable level, an approved respirator must be worn. Respirator type: N95 Particulate Filter. If respirators are used, a programPrinted: 10/28/2003 Report Version: 1 . 000008201/F/USA Approval Date: 09/24/2002 Page: 3/3 MATERIAL SAFETY DATA SHEET 

# fONFIDENTfAL

should be instituted to assure compliance with OSHA Standard 29 CFR 1910.134. Eye Protection: Wear safety glasses with side shields (or goggles). Skin Protection: Wear impervious gloves and protective clothing appropriate for the risk of exposure. Recommended impervious materials: Neoprene rubber. Recommended Decontamination Facilities: Eye bath, washing facilities, safety shower
9. PHYSICAL AND CHEMICAL PROPERTIES Physical Form: Solid Color: vJhite Odor: Odorless Specific Gravity (water 

### = 1): Not available Vapor Pressure: Not available Vapor Density (Air = 1): Not available Volatile Fraction by Weight: Not available Melting Point: Not available Solubility in Water: Not available pH: Not applicable Flash Point: Not applicable, combustible solid
10. STABILITY AND REACTIVITY Stability: Stable. Safe handling temperatures are dependent on specific conditions of use and are typically substantially below the onset temperature. Consult your technical safety experts. Exotherm onset temperature: 297°C by DSC Incompatibility: Strong oxidizing agents. Hazardous Polymerization: Will not occur.
11. TOXICOLOGICAL INFORMATION Effects of Exposure:

General: The toxicological properties of this material have not been fully investigated and its handling and use may be hazardous. Toxicity evaluation of**thi~_chemical** is based, in part, on a structurally similar chemical



### ___ J). May cause blood disorders based on anlmal data. Inhalation: Harmful if inhaled. Causes sneezing. May cause irritation to the mucous membranes and upper respiratory tract. Eyes: Causes irritation. Skin: Harmful if absorbed through skin. Causes irritation. Ingestion: Harmful if swallowed. May cause irritation of the gastrointestinal tract. Acute Toxicity Data: Oral LD-50 (rat): > 2000 mg/kg Acute Toxicity Data for•Printed: 10/28/2003 Report Version: 1 . 000008201/F/USA Approval Date: 09/24/2002 Page: 4/4 MATERIAL SAFETY DATA SHEET

(

# ________________________ 

# CONFIDENTIAL

Oral LD-50 (rat): 400-3200 mg/kg (target**orga;~** effects: blood) Skin irritation: slight to moderate
12. ECOLOGICAL INFORMATION Introduction: This environmental effects summary is written to assist in addressing emergencies created by an accidental spill which might occur during the shipment of this material, and, in general, it is not meant to address discharges to sanitary sewers or publically owned treatment works. Summary: Data for this material and chemically similar materials have been used to estimate the environmental impact of this material. However, this material, itself, has not been tested for environmental effects. It is expected to have the following properties: a moderate biochemical oxygen demand and may cause oxygen depletion in aqueous systems, a low potential to affect aquatic organisms, a moderate potential to affect secondary waste treatment microbial metabolism, a high potential to biodegrade (low persistence) with unacclimated microorganisms from activated sludge, a low potential to bioconcentrate. After dilution with a large amount of water, followed by secondary waste treatment, this material is not expected to cause adverse environmental effects.
13. DISPOSAL CONSIDERATIONS Discharge, treatment, or disposal may be subject to national, state, or local laws. Incinerate. Since emptied containers retain product residue, follow label warnings even after container is emptied.
14. TRANSPORT INFORMATION For 30 grams or less:

United Nations UN Number: None, not regulated USA Department of Transportation (DOT) Hazardous Materials Classification: DOT (USA) Status: Not regulated DOT Hazardous Substance(RQ): No Marine Pollutant: No For other transportation information, call the Kodak Worldwide Transportation Hazmat Hot Line: (585) 722-2400 between 8 a.m. and 5 p.m. (Eastern Standard Time), Monday through Friday.
15. REGULATORY INFORMATION

- Material(s) known to the State of California to cause cancer: None

- Material(s) known to the State of California to cause adverse reproductive

effects: None

- Carcinogenicity Classification (components present at 0.1% or more):

- International Agency for Research on Cancer (IARC): None

American Conference of Governmental Industrial Hygienists (ACGIH) None

- National Toxicology Program (NTP): None

- Occupational Safety and Health Administration (OSHA): NoneMATERIAL SAFETY DATA SHEET Printed: 10/28/2003 Report Version: 1 . 000008201/F/USA Approval Date: 09/24/2002 Page: 5/5

- Chemical(s) subject to the reporting requirements of Section 313 or Title III of the Superfund Amendments and Reauthorization Act (SARA) of 1986 and 40 CFR Part 372: None 16. OTHER INFORMATION US/Canadian Label Statements: WARNING' MAY CAUSE BLOOD DISORDERS BASED ON ANIMAL DATA**HAR~lFUL** IF INHALED, ABSORBED THROUGH SKIN, OR SWALLOWED CAUSES SKIN AND EYE IRRITATION POWDERED MATERIAL MAY FORM EXPLOSIVE DUST-AIR MIXTURES CAN DECOMPOSE AT ELEVATED TEMPERATURES CAUSES SNEEZING THE TOXICOLOGICAL PROPERTIES OF THIS !1ATERIAL HAVE NOT BEEN FULLY INVESTIGATED HEALTH HAZARD EVALUATION BASED, IN PART, ON DATA FOR A STRUCTURALLY SIMILAR MATERIAL Minimize dust generation and accumulation. Avoid breathing dust. Avoid contact with eyes, skin, and clothing. Keep container closed. Use with adequate ventilation. Wash thoroughly after handling. FIRST AID: If swallowed, only induce vomiting as directed by medical personnel. Never give anything by mouth to an unconscious person. Call a physician or poison control center immediately. If inhaled, move to fresh air. Treat symptomatically. In case of contact, immediately flush eyes and skin with plenty of water for at least 15 minutes while removing contaminated clothing and shoes. Get medical attention if symptoms occur. Wash contaminated clothing before reuse. Destroy or thoroughly clean contaminated shoes. Keep out of reach of children. Do not handle or use until safety precautions in Material Safety Data Sheet (MSDS) have been read and understood. Additional hazard precautions for containers greater than 1 gallon of liquid or 5 pounds of solid: Since emptied containers retain product residue, follow label warnings even after container is emptied. IN CASE OF FIRE: Use water spray, carbon dioxide (C02), dry chemical. IN CASE OF SPILL: Sweep or scoop up and remove.
The information contained herein is furnished without warranty of any kind. Users should consider these data only as a supplement to other information gathered by them and must make independent determinations of suitability and completeness of information from all sources to assure proper use and disposal of these materials and the safety and health of employees and customers and the protection of the environment.

# 17

# fONFIDENTIAL FINAL REPORT

HAELNo..;j_
__ _

## KAN:'~ 

# J**CIN:~I** CAS No.:( 

# ____,., P2-2003-015 Page 1of 18



### STRUCTURE-ACTIVITYESTIMATIONS OFHEALTHAND ENVIRONMENTAL FATEAND EFFECTS

AUTHORS Rodney J. Boatman, Ph.D. Marianne P. 1-lirsch, Ph.D.
TESTINGFACll.JTY Toxicological Sciences Section Health and EnvironmentLaboratories Eastman Kodak Company Rochester, NY 14652-6278 USA
STUDY SPONSOR Eastman Kodak Company
STUDY COMPLETIONDATE October 27, 2003

### P2-2003-015 Page 2 of 18 GOOD LABORATORY PRACTICE COMPLIANCE STATEMENT
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# zq

### SIGNATUREPAGE P2-2003-015 Page 3 of 18

STRUCTURE-ACTIVITY ESTIMATIONS OF HEALTH AND ENVIRONMENTAL FATEAND EFFECTS

Mari ne P. H1rsch, Ph.D. SeniorToxicologist Ecotoxicology

Rodney J. Boarlnan, Ph.D., DABT Technical Associate Biochemica] and Analytical Toxicology

Director Toxicological Sciences



# 3o 

# 6!JcJu ,_.9.], JCC3 Month/Day/Year



### Oc".**21>zoo~** 

### Month/Day/Year 

# aJk g.j,acoJ Month/Day/Ye;tl-



# ...

### TABLE OF CONTENTS

CHEMICAL IDENTIFICATION INFORMATION TestingFacility Project Participants Sponsor Chemical Structure Chemical Characterization 

### ABSTRACT INTRODUCTION AND METHODS RESULTS AND CONCLUSIONS REFERENCES APPENDIX 1. 

### Output from the EPI ComputerProgram 

### APPENDIX 2. Output from E-FAST ComputerProgram 

### APPENDIX 3. Output from ECOSAR ComputerProgram 

### APPENDIX 4. Output from the PBTProfiler 

### APPENDIX 5. Output from the DEREKTM ComputerProgram



# 31 P2-2003-015 Page4 of 18
Page Number 5 5 5 5 

### 5 5 6 

### 7 7 

### 9 10 

### 12 13 

### 17 18

# CONFIDENTIAl CHEMICALIDENTIFICATION INFORMATION TestingFacility Toxicological Sciences Health and EnvironmentLaboratories Eastman Kodak Company Rochester, New York 14652-6278 USA 

### ProjectParticipants Report Authors: 

### Sponsor Eastman Kodak Company 

### Chemical Structure 

# (

Chemical Characterization Chemical Name: HAELNo.: KAN: MolecularFormula: Rodney 

### J. Boatman, Ph.D. Marianne P. Hirsch, Ph.D. P2-2003-015 Page 5 of 18


# )

MolecularWeight: CAS No.: CIN: 441.714 

# r L
___ _**L~- ~~~-----------J**  Neutral organics-acid Sl\1ILES: Classification (ECOSAR):

# fONFIDENTIAL P2-2003-015 Page 6 of 18 STRUCTURE-ACTIVITYESTIMATIONS OF HEALTH AND ENVIRONMENTAL FATE AND EFFECTS

HAELNo.: KAN: CAS**No.~** 

### CIN:
ABSTRACT Environmental The environmental fate and effects ofthe test substance were estimated by using the EPI Suite, ECOSAR, E-FAST, and PBTProfilercomputerprograms. The ECOSAR program predicted the 48-hourEC50 

### value for daphnids, the 96-hourLC50 

### value for fish, and the 72-hourECso value for growth ofgreen algae to be greaterthan the calculated aqueous solubility of the test substance (>6.0 mg!L). ThePBT Profilerpredicted that this material would not be classified as a PBT chemical ofconcern. TheE-FASTcomputerprogram predicted that the wastewatertreatment facility at Kodak Park would not discharge effluent containing the test chemical at concentrations greaterthan the concentration ofconcern (296 flg/L) for this material during manufacturing operations.
Health
Dueto a lack ofa carcinogenic determinant, the OncoLogic® computerprogram was not run for this compound. In addition, the DEREKTMcomputerprogram did not identify any structural alerts for toxicity. Limited datafor the test substance and the sodium salt analog also suggest a low potential for toxicity.

# CONFIDENTIAL P2-2003-015 Page 7 of 18 

### STRUCTURE-ACTIVITYESTIMATIONS OFHEALTH AND ENVIRONMENTAL FATEAND EFFECTS

HAEL No.:(
___ 

# :J CASNo.:f 

# KANC J CIN:**~~-----**

### __**~)** 

### INTRODUCTIONAND METHODS Structure-activityrelationships (SARs) were used to predict the environmental fate and aquatic toxicity ofthe test substance. Structures were enteredinto computerprograms using the SMll.,ES (Simplified Molecular Input Line EntrySystem) notation [1]. The Estimation Programs Interface (EPI Suite) computerprogram developed by Syracuse Research Corporation [2] was used to compute estimates ofthe log 

## Kow value and estimates ofenvironmental fate and bioconcentration factorfor this chemical. TheECOSAR computer program was used to obtain estimates for the aquatic toxicity ofthischemical [3]. The PBTProfilercomputerprogram [ 4] was used toprovide an estimate ofthe persistence and bioaccumulation ofthe test chemical. Carcinogenic potential was not estimatedusing the expert system OncoLogic® [5] as the chemical did not contain any structural alerts for carcincogenicity. Mammalian target organ toxicity was evaluated using the DEREKTM computermodeling program [6] and animal toxicity testing for the test chemical and the sodium salt analog.


### RESULTS AND CONCLUSIONS Environmental Persistence (P2) The BIOWIN model withinEPI Suite [2] computerprogram predicted a high probability ofrapid biodegradation, and the Ultimate SurveyModel estimated mineralization would occurwithin the timeframe of "weeks-months". ThePBTProfilerpredicted that the substance is likelyto exhibit low persistencein water, moderatelypersistent in soils, and highly persistent in sediments [4]. Therefore, the test substance is likely to be persistent in the environmental media to which it is expected to partition: water (15%), soil (76%), and sediment (10%). ··· Bioconcentration (Bl) The KOWWINmodel within the EPI Suitecomputerprogramestimated the log

## Kow to be4.43 [2]. Using the estimated log

## Kow of4.43, the BCFWIN model calculated a bioconcentration factor of70.8 [2]. This BCFvalue indicates the test substance is unlikely to bioconcentrate in aquatic organisms.

### Toxicity (Tl) P2-2003-015 Page 8 of 18
The ECOSAR program predicted the 48-hourEC50 

### value for daphnids, the 96-hourLCso value for fish, and the 72-hourEC50 

### value for growth ofgreen algae to be greaterthan the calculated aqueous solubility ofthe test substance (>6.0 mg!L). According to U.S. EPA assessment criteria, the test substance would be classified as being in the "low concern level" category [8]. Aquatic Environment Exposure/Risk The following values were used as input for theE-FAST program: manufactured at a rate of 300 kg/batch (4 batches/yr) with 1kg/batch going to waste, and 52% removal during wastewater treatment. TheE-FAST computerprogram [9] predicted that the wastewater treatment facility at Kodak Park would not discharge effluent containing the test chemical at concentrations greater than the concentration ofconcern (6000 )-tg/L) 

### for this material during manufacturing operations.


### Health Carcinogenicity and Mammalian Toxicity (Tl) Due to a lack ofa carcinogenic determinant, the OncoLogic® computerprogram was not run for this compound [5]. Based on animal toxicity testing, this chemical is not acutely toxic by the oral route. No other data are available for the test chemical. The sodium salt analog (CAS# 137-20-2) was not acutely toxic bythe oral ordermal routes. Irritancy was consistent with that observedfor other anionic surfactants. A reduction in platelet count was observed in a 2-week gavage study in three rats; however, clotting time was not affected [7]. The DEREKTM computerprogram [6] was also used to predict the potential toxicological hazards ofthe test substance (Appendix 5). This analysis revealed no structural alerts for toxicity. Limiteddata for the test substance and the sodium salt analog also suggest a low potential for toxicity. Site-Specific Human Exposure from Drinking Water and Fish Consumption Based on estimatedrelease oftest substance to the Genesee River from manufacturing operations in Rochester, New York, human intake from drinking water was calculatedtobe 1.15 X 

### 10"8 

### mg/kg/day [9]. Similarly, human intake from fish consumption was estimatedto be 3.49 x 10-9 

### mg/kg/day [9]. Given such low estimatedhuman exposure levels, no human health hazard is anticipated due to release ofthis material to the environment from manufacturing operations.



# 35

## REFERENCES P2-2003-015 Page 9 of 18

1. Weininger, A. 1988. "SMll__ES, a Chemical Language and Information System. 1. Introduction to Methodology and Encoding Rules." J. Chern. Inf. Comput. Sci. 28:31-36. 2. Meylan, W. 1993. User's Guide for the Estimation Programs Interface (EPI), Version 1.2, Syracuse Research Corporation, Syracuse, NY 13210. 3. Nabholz, J.V. and Cash, G. 1998. ECOSAR Class Program, MS-Windows Version 0.99, United States Environmental Protection Agency, Health and Environmental Review Division, Environmental Effects Branch, Washington, DC. 4. PBTProfiler, "U.S. EPA- OPPT, A Component ofOPPT's P2Framework", Version 1.203; www.pbtprofiler.net. 5. Woo, Y-T., Lai, D.Y., Argus, M.F., and Arcos, J.C. 1995. "Development ofStructureActivity RelationshipRules for Predicting Carcinogenic Potential ofChemicals", Toxicol. Lett. 79:219-228. 6. Greene, N., Judson, P.N., Langowski, 

### J.J., Marchant, C.A. 1999. "Knowledge-Based Expert Systems for Toxicity andMetabolismPrediction: DEREK," SAR QSAREnviron. Res. 10:299-314. 7. Eastman Kodak Company. 1985. Unpublished data submittedtoEPA underTSCA Section 8(d). 8. Srnrchek, J., Clements, R., Morcock, R., and Rabert, W. 1993. "AssessingEcological HazardUnderTSCA: Methods and Evaluation ofData," Environmental Toxicologyand Risk Assessment, ASTM STP 1179, W. Landis, J.S. Hughes, andM.A. Lewis, Eds., American SocietyforTesting andMaterials, Philadelphia, pp. 22-39. 9. Brennan, T., U.S. EPA- OPPT, "E-FAST- Exposure and FateAssessment Screening Tool", beta version, www.epa.gov/opptintr/exposure.

### P2-2003-015 Page 10 of 18 Appendix 1. 

### Output from the EPI ComputerProgram [2] SMILES :[ CHEM : 

# J 

# fONF1DENTIAL
MOL FOR: 

### j MOL WT :**-::;4:r0i'i3:-.c6'""~3,-------...J** EPI SUMMARY (v3.11)

Physical Property Inputs: Water Solubility (mg/L): Vapor Pressure (mm Hg) Henry LC (atm-m3/mole) Log Kow (octanol-water): Boiling Point (deg C) Melting Point (deg C) Log Octanol-Water Partition Coef (SRC): Log Kow (KOWWIN v1.67 estimate) = 4.43 Boiling Pt, Melting Pt, Boiling Pt (deg C) : Melting Pt (deg C): Vapor Pressure Estimations (MPBPWIN v1.41): 539.51 (Adapted Stein & Brown method) 231.05 (Mean or Weighted MP) VP(mm Hg,25 deg C): 6.92E-014 (Modified Grain method) Water Solubility Estimate from Log Kow (WSKOW vl.41): Water Solubility at 25 deg C (mg/L): 0.4748 log Kow used: 4.43 (estimated) no-melting pt equation used Water Sol Estimate from Fragments: Wat Sol (v1.01 est) 

### = 28.996 mg/L ECOSAR Class Program (ECOSAR v0.99g):**Class~es)** found: Neutral Organics-acid Henrys Law Constant (25 deg C) [HENRYWIN v3.10]: Bond Method : 1.00E-012 atm-m3/mole Group Method: Incomplete Henrys LC [VP/WSol estimate using EPI values]: 7.740E-014 atm-m3/mole Probability of Rapid Biodegradation (BIOWIN v4.01): Linear Model 0.9823 Non-Linear Model 0.9998 Expert Survey Biodegradation Results: Ultimate Survey Model: 2.7439 (weeks-months) Primary Survey Model : 3.9170 (days } Readily Biodegradable Probability (MITI Model): Linear Model 0.4418 Non-Linear Model 0.2188 Atmospheric Oxidation (25 deg C) [AopWin v1. 91] : Hydroxyl Radicals Reaction: OVERALL OH Rate Constant OVERALL OH Rate Constant Half-Life = 1.288 Hrs Half-Life= 1.197 Hrs Ozone Reaction: 99.6298 E-12 cm3/molecule-sec**[Cis-isome~·** 107.2298 E-12 cm3/molecule-sec [Trans-isomer] (12-hr day; 1.5E6 OH/cm3} [Cis-isomer] (12-hr day; 1.5E6 OH/cm3} [Trans-isomer] OVERALL Ozone Rate Constant OVERALL Ozone Rate Constant 13.000000 E-17 cm3/molecule-sec [Cis-] 20.000000 E-17 cm3/molecule-sec [TransHalf-Life = 2.116 Hrs (at 7E11 mol/cm3) [Cis-isomer] Half-Life = 1.375 Hrs (at 7Ell mol/cm3) [Trans-isomer] Reaction With Nitrate Radicals May Be Important! Soil Adsorption Coefficient (PCKOCWIN v1.66}: Koc 2.538E+004 Log Koc: 4.404**2)~**

### P2-2003-015 Page 11 of 18 Aqueous Base/Acid-Catalyzed Hydrolysis (25 deg C) [HYDROWIN v1.67]: Rate constants can NOT be estimated for this structure! BCF Estimate from Log Kow (BCFWIN v2.15): Log BCF 

### = 1.850 (BCF 

### = 70.79) log Kow used: 4.43 (estimated) Volatilization from Water: Henry LC: 1E-012 atm-m3/mole (estimated by Bond SAR Method) Half-Life from Model River: 1.176E+009 hours (4.901E+007 days) Half-Life from Model Lake : 1.283E+010 hours (5.347E+008 days) Removal In Wastewater Treatment (recommended maximum 99%) : Total removal: 52.30 percent Total biodegradation: 0.49 percent Total sludge adsorption: 51.80 percent Total to Air: 0.00 percent Level III Fugacity Model: Mass Amount Half-Life Emissions

(percent) (hr) (kg/hr) Air 0.0715 1.16 1000 Water 25.7 900 1000 Soil 65.1 900 1000 Sediment 9.15 3.6e+003 0 Persistence Time: 710 hr

·

## ..

# CONFIDENTIAL
Appendix 

### 2. Output from the ECOSAR ComputerProgram [3]

SMILES

# :I~ 

# J
CHEM :

# L

- CAS Num:**----------------------------------------~** ChemiD1: ChemiD2: ChemiD3: MOL FOR:( MOL WT : 4(T3. 63 Log Kow: 4.43 (User entered) Melt Pt: Wat Sol: 5.962 mg/L (calculated) ECOSAR v0.99g Class(es) Found Neutral Organics-acid
ECOSAR Class Organism Duration End Pt Neutral Organic SAR (Baseline Toxicity) Fish 14-day LC50

--> Acid moeity found: Predicted values multiplied by 10 Neutral Organics-acid Fish 96-hr LC50 Neutral Organics-acid Fish 14-day LC50 Neutral Organics-acid Daphnid 48-hr LC50 Neutral Organics-acid Green Algae 96-hr EC50 Neutral Organics-acid Fish 30-day ChV Neutral Organics-acid Daphnid 16-day EC50 Neutral Organics-acid Green Algae 96-hr ChV Neutral Organics-acid Fish (SW) 96-hr LC50 Neutral Organics-acid Mysid Shrimp 96-hr LC50

Neutral Organics-acid : Earthworm 14-day LC50

Note: * 

### = asterick designates: Chemical may not be soluble enough to measure this predicted effect.

Fish and daphnid acute toxicity log Kow cutoff: 5.0 Green algal EC50 toxicity log Kow cutoff: 6.4 Chronic toxicity log Kow cutoff: 8.0 MW cutoff: 1000 

### P2-2003-015 Page 12 of 18

Predicted mg/L (ppm) 4.144

15.552 * 41.443 * 19.710 

### * 14.172 *

2.964 2 0 927 50 772 11.537 *

0.792 mg/kg (ppm) dry wt soil



### ----------- -----------

4431.375 *

·

## ..

### Appendix 3. Output from theE-FASTComputerProgram [91


## II ENVIRONMENTALRELEASES Scenario#: 1 

### Number ofRelease Sites: 1. 

### Release Activity: Manufacture Release Description: WATER LANDFILL INCINER LANDIINCIN lfotal Releases: 4.00 0.00 0.00 0.00 (kg/yr) (kg/yr) (kg/yr) (kg/yr) Release Days/yr: 4. IPer Site Release: 1.00 0.00 0.00 0.00 (kg/day) (kg/yr) (kg/yr) (kg/yr) P2-2003-015 Page 13 of 18

FUGITIVE 0.00 (kg/yr) 0. 0.00 (kg/day)

### P2-2003-015 Page 14 of 18

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACEWATER RELEASES SCENARIO#: 1 RELEASE ACTIVITY: Manufacture FACILITY NAME: EASTMAN KODAK COMPANY FACILITY LOCATION: ROCHESTER NY 14652 RECEIVING WATER NAME: GENESEE RIVER FACILITY ON REACH: No DICHARGETYPE: Indirect REACHNUMBER: 04130003001 NPDES PERMIT#: NYOOO1643 DATA SOURCE: FacSrch EXPOSED POPULATION: Adult WWTREMOVAL RELEASE PRE-TREAT POST-TREAT BCF 

### (%) DAYS RELEASE (kg/day) RELEASE (kg/day) (L/kg) 52. 4. 1. 

### 0.48 70.80 AQUATIC EXPOSUREESTIMATES- SURFACEWATER FLOWDESCRIPTOR Harmonic Mean 30Q5 7Q10 lQlO PLANT FLOW(MLD) 3565.86 1528.48 1054.22 851.76 NA CONCENTRATION (Jlg/L) 

### 0.13 0.31 0.46 0.56 NA



# 41

### DRINKING WATER INGESTIONEXPOSUREESTIMATES ASSUMPTIONS Exposure Units Results ED AT BW (years) (years) (kg) Cancer LADDro, (mg/kg/day) 1.15E-08 30.00 75.00 71.80 LADCro, (mg/L) 5.90E-07 30.00 75.00 NA Chronic Non-Cancer ADDro, (mg/kg/day) N/A 30.00 30.00 71.80 ADCpo, (mg!L) N/A 30.00 30.00 NA Acute ADRpo, (mg/kg/day) N/A 1.00 day 1.00 day 71.80

FISHINGESTIONEXPOSUREESTIMATES ASSUMPTIONS Exposure Units Results ED AT BW (years) (years) (kg) Cancer LADDpo, (mg/kg/day) 3.49E-09 30.00 75.00 71.80 LADCpo, (mg/kg) 4.18E-05 30.00 75.00 NA Chronic Non-Cancer ADDpo, (mg/kg/day) N/A 30.00 30.00 71.80 ADCpo, (mglkg)
. N/A 30.00 30.00 NA Acute ADRpo, (mg/kg/day) .N/A 1.00 day 1.00 day 71.80 P2-2003-015 Page 15 of 18

IR (L/day)
1.40 NA
1.40 NA
6.00

IR (g/day)
6.00 NA

.• < 

### 6.00 NA
129.00

# I P2-2003-015 Page 16 of 18

SITE-SPECIFICHUMAN AND AQUATIC EXPOSURES TO SURFACEWATER RELEASES SCENARIO#: 1 RELEASE ACTIVITY: FACILITY NAME: EASTMAN KODAK COMPANY FACILITY LOCATION: ROCHESTER NY 14652 RECEIVING STREAM NAME: GENESEE RIVER 

### REACH NUMBER: 04130003001 NPDES PERMIT#: NY0001643 PERIOD OF RECORD:N/A 50%ILE FLOW: 6914.60



# coc ()lg/L) 

### % yrexceeded 6000.00 0.00 FACILITY ON REACH: Yes DATA SOURCE: FacSrch #OBSERVATIONS: N/A 10%ILEFLOW: 1054.22 RESULTS Days/yr Release exceeded days/year 0.00 4.00 DISCHARGETYPE: Direct STATION ID: N/A #STATIONS ON REACH: N/A EFFLUENTFLOW:126.89 Loading Waste Water (kg/site/day) Treatment (%) 1.00 52.00 

# I

# fONFIDENTIAL
Appendix 4. 

### Output from the PBT Profiler [4] 

### P2-2003-015 Page 17 of 18

t"1ethodolo,gy · Criteria · Definitions · Chemicals ThatShould Notbe Profiled
_

- -- ·-·-·- ·------·-·--··-------------·-- --··-·-------·-- ··-··--·---- -·---- --·--· ----···-·-···-··-·--·-····-·-·--··-----·--·-····-···-··--···----- :

# "'

Home Star1: a 

### [',Jew Profile F<esults Terms ofUse Secur-it'y 

## i;O
Results Italicized or underlined highlights indicate that the EPA criteria have been exceeded. Color version 

### Persistence Bioaccumulation Toxicity

Media

Water Soil Sediment Air Half-Life (days)



### 38 

### 75 340 0.058 

# c PBT Profiler Estimate 

## =P b t

- 15% 

### Percentin Each Medium

---•76% • 10%

0% 

### P2 Considerations and more information 

## * The predicted water solubility, 0.47 mg/1, is less than the estimated ChV, 3 mg/l. There maybeno effect at saturation.

The PBTProfilerResults are available for 20minutes 

### BCF 

### 71 Fish ChV (mg/l)



### 3*

Developedbythe Environmental Science Center undercontract to the Office of Pollution Prevention and Taxies, U.S. EnvironmentalProtectionAgency ComputerResources DonatedbySyracuseResearch Corporation Ver 1.203 Last UpdatedMay 20, 2003 

# 41

### Appendix 5. Output from the DEREKTM ComputerProgram [6] H\KAN75556l_DEREKrtf 

## DEREKfor Windows report L116025 Date Created: Wednesday, October 08, 2003 Version: 6.0.0 Database: H:\Dfw6.mdb DatabaseVersion: DFW6.0.0_2002_07_18 User Name: Lll6025 Testing Against: All Alerts Species: mammal SuperEndpoints: Carcinogenicity Irritation Miscellaneous endpoints Mutagenicity Respiratory sensitisation Skin sensitisation Thyroid toxicity ConsiderTautomers: On Log Kp: -2.786 Calculated by the Potts & Guy equation LogP: 3.702 Calculated by the Moriguchi estimation Molecular Weight: 441.712 Calculated by LPS Compound Name(_
___ _ Submitted Compound:

List ofalerts found: Nothing to report 

### P2-2003-015 Page 18 of 18 

# CONFIDENTIAl

·-.

### FIN/{L REPORT 

# (
__ 0)
HAELNo.:( CAS No.: Not Available ES-98-050 Page 1

### of 14 

# CONFIDENTIAL 

# KAN:CJ CIN:

- . _
ACTIVATED SLUDGE RESPIRATION INHIBITION SCREENING TEST

AUTHOR Janice M. Beglinger, B.S.

TESTING FACILITY Environmental Sciences Section Health and Environment Laboratories Eastman Kodak Company Rochester, New York 14652-6278 USA

STUDY SPONSOR Eastman Kodak Company

STUDY COMPLETION DATE July 16, 1998

### ES-98-050 Page 2 of 14


### GOOD LABORATORY PRACTICE COMPLIANCE STATEMENT

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# 17

### SIGNATURE PAGE ES-98-050 Page 3 of 14



### ACTIVATED SLUDGE RESPIRATION INHIBITION SCREENING TEST

Principal Investigator/Report Author

Unit Director, Environmental Sciences Section



# 18 Month/Day/Year

# J~.JJ 

# '',19>o Month/Day/Year

### TABLE OF CONTENTS

ABSTRACT STUDYAND TEST SUBSTANCE INFORMATION Testing Facility Sponsor Study Dates Project Participants Test Substance Characterization Composition and Stability Determination Positive Control 

### PURPOSE MATERIALS AND METHODS Test System Experimental Design Analytical Measurements Data Storage DataEvaluation and Interpretation Calculations Test Validity 

### RESULTS DISCUSSION CONCLUSION REFERENCES TABLE ES-98-050 Page 4 of 14

Page Number 

### 5 6 6 6 

### 6 6 6 

### 6 7 

### 7 

### 7 

### 7 7 

### 8 8 

### 8 9 

### 9 9 10 10 11
Table 

### 1. Preparation ofSyntheticFeed and Positive Control Solutions 12 Table 2. Dissolved Oxygen Worksheetfor Test Substance 13 Table 3. Dissolved Oxygen Worksheet for Positive Control 14

### .HAELNo.:(_;;.- 

# J CAS No.: NotAvailable 

# CONFIDENTIAL c

__ ) ES-98-050 Page 5 of 14


# KANo· CIN:
_ ACTIVATED SLUDGERESPIRATION INHIBITION SCREENING TEST

ABSTRACT A 3-hour activated sludge respiration inhibition screening test was performed using activated sludge from an industrial waste watertreatmentplant. The sludge microorganisms were exposed to replicates ofthe test substance at one concentration, nominally 1 000 mg/L. Aeration ofthe test solution resulted in foaming, which lasted throughout the test period. Foaming ofthe test solutionwhen aerated, maybe a significant effect depending upon the use ofthe test substance. Foaming may also be a concern for waste watertreatment as such facilities are aerated. The respirationrate, expressed as oxygen consumption by the microbes in mg 

### 02 per literperhour, was measured under defined conditions following the 3-hour exposure period. Inhibition values were calculated by comparingtest respiration rates to negative control rates. The only concentrationtested, 1000mg/L, resulted in 26.6% and 27.5% inhibition. Therefore, the EC50 is 

### >1000mg/L. A no-observed-effect concentration (NOEC) could not be obtained for this test.



# 50

### ES-98-050 Page 6 of 14
STUDY AND TEST SUBSTANCE INFORMATION TestingFacility Environmental Sciences Section Health and Environment Laboratories Eastman Kodak Company Rochester, New York 14652-6278 USA Sponsor Eastman Kodak Company StudyDates Sludge Collection Date: Experimental Start Date: Experimental Termination Date: ProjectParticipants Biodegradation Coordinator: June 9, 1998 June 10, 1998 June 10, 1998

Principal Investigator/Report Author: Test Substance Characterization Test SubstanceName: HAELNo.: KAN: 

# 0

CAS No.: NotAvailable CIN: 

### SRID orLotNo.: 

# [ 

# ' Physical State and Appearance: White solid 

# fONFIDENTIAL

Charles J. 

### Ruffing, Ph.D. .nillice M. Beglinger, B.S.

Solubility: Not available at test time Composition and Stability Determination Composition: The composition ofthis substance was not verified for this screening assay. Stability Determination: As part ofthis test, the test substance is exposed to activated sludge, which may degrade the test substance. This study is designed to measure effects ofthetest substance and/or any decomposition products. 

# '51

### Positive Control Identity: CAS Reg. No.: Purity: 3,5-dichlorophenol 591-35-5 99.2% PURPOSE ES-98-050 Page 7 of 14

The purpose ofthis screen is to identify substances that may have adverse effects on aerobic sludge microorganisms from waste watertreatmentplants. The method described assesses the effect ofa test substance on microbial respiration. Therespirationrate, expressed as oxygen consumptionby the microbes in mg 02perliter per hour, is measured underdefined conditions inthe presence ofthe test substance. The data may be used to estimate thepotential for microbial inhibition at the exposure concentration. MA TERJALS AND METHODS 

### Test System Activated sludge microorganisms were collected from an industrial waste water treatment plant. Viability ofthe microorganisms was confirmed on receipt in the laboratory and activity checked by means ofa positive control. In studies ofthis sort no attempt is made to identifY the large variety oforganismspresent in the samples orthe degree ofabsorption ofthe test and control substances. Experimental Design Preparation ofthe Inoculum On return to the laboratory, the sludge was aerated and stirred at 20 

### ±2°C. A small amount ofthe fresh sludge was weighed, oven-dried, and reweighed to determine the oven-dried MLSS determination ofthe fresh sludge in g/L. The sludge was used, as is, the day it was received. ThepH ofthe sludge was 7.4 77. Afterthe initial test, it was aerated and fed**~30** 

### mL each ofthe Organic Stock and the Phosphate Stock solutions. The sludge wasthen usedthe following day torepeatthe test substanceportionofthe study. Preparation ofTest Solutions 1. Synthetic Feed Stock Solutions: see Table 1. 2. Positive Control Stock Solution: 3,5-dichlorophenol, a known inhibitor ofmicrobial respiration, was used as thepositive control (Table 1 ). 3. Test Substance: the test substance was added directly to the test beakers.

### Experimental Design, continued Test Procedure ES-98-050 Page 8 of 14

In typical respiration inhibition studies, 1-literbeakers are used as the test vessels. At time "0", 

### 8 mL ofeach synthetic feed stock solution was placed in a 200 mLvolumetric flask and brought to volume with distilled water. Next, 100 mL ofdistilled waterwas added to the beaker, andthen, 200 mL ofsludgewas added to give a final volume of500 mL. This mixture was placed in the Negative Control beaker. A 5 mL sample was removed from the first Negative Control to determine the final sludge concentration in the test beakers. Aeration at**~0.8** 

### Llmin was started using a pipet as an aeration device. Test solutions were set at 12 minute intervals. At time "12 min" (12 minutes is an arbitrary, but convenient, interval) the above was repeated for the secondbeakercontainingthe limit dose ofthe test substance. Thetest substance was added directly to the test solution. The theoretical concentration ofthe test substance was 1000 mg/L. The third test vessel was a replicate ofthe 1000 mg/L. Test substance solutions were tested in 2-literbeakers to contain any foam produced. Finally, a secondNegative Control was prepared. Oxygen consumption was measured and recorded after an aeration time ofthree hours at 22°C. Onthe previous day, the positive control was tested on the microbial inoculum in the same way, exceptthat 100 mL ofthe positive control stock solution were placed in the beakers instead ofdistilledwater. The process was repeated at 12-minute intervals to give a series of theoretical concentrations ofthe positive control in the test vessels of31.25, 

### 9.77, and 3.05 mg/L. 

### Analytical Measurements DOMeasurements Afterthree hours, a standard BOD measuring bottle was filled from the contents ofthe first beaker andthe respirationrate was measured overa period ofapproximately 9 minutes using a dissolved oxygenmeterhooked upto a recording chart. This determination was repeated on the contents ofeach vessel at 12-minute intervals so that the exposure time in each beaker wasthreehours. 

### Data Storage All rawdata and summaries ofdata will be retained for at least ten years in the testing facility archive managed under GLP-mandated conditions. 

# 53

### Data Evaluation and Interpretation ES-98-050 Page 9 ofl4

Lotus 1-2-3 was used for data calculations. No attemptwas made to determine potential adsorption ofthe test substanceto the sludge orpotential biodegradation ofthe chemical by the microorganisms. The 

## ECso value (ifcalculated) should be regarded merely as a guide to the likely toxicity ofthe test substance to activated sludge during waste watertreatment 

### andto microorganisms during biodegradability testing. The complex interactions occurring in the environment may not be accurately simulated in a laboratorytest. Calculations The respiration rate was calculated from the recordertrace as mg 02perliterperhour between approximately 6.5 mg 02/L and 2.5 mg 02/L, orover a 9-minute period when therespiration rate is low. The respiration rate was measured where the curve was approximately linear. In orderto calculate the inhibitory effect ofa test substance at a particularconcentration, the respiration rate is expressed as a percentage ofthe mean ofthe two control respiration rates: (1 - 

### 2RS--) x I

### 00 = % inhibition Rcl 

### +Rc2 where: Rs =oxygen-consumption rate at tested concentration oftest substance Rc1 = oxygen-consumptionrate, Control 1 Rc2 =oxygen-consumptionrate, Control 2 The percent inhibition was calculated at each test concentration as above, plotted against concentration, and an 

## ECso value derived together with aNOEC. Regression analysis may prove useful, and 95% confidence limits for the 

## ECso values can be determined using standard procedures. In view ofthe variability often observed in the results, these may be expressed, if desired, in orders ofmagnitude (i.e., less than 1, 1to 10, 10to 100, etc., in mg/L). TestValidity The two negative control respiration rates were within 

### 15% ofeach other and the 3-hour

## ECso value of3,5-dichlorophenol was in the range 5 - 

### 30mg!L. Theseresults meetthe criteriafor a validtest. RESULTS The final sludge concentration in the test beakers ofthe initial test was 2.2 giL. 

### Valid results for the test substance were not available from the first study. Excessive foaming ofthe test solution when aerated resulted in turning the aeration off. Stirring did not allowfor sufficient aeration of the test substance solution. The positive control concentrations were not affected and the results were used. Thepositive controls (concentration 31.25, 9.77, and 3.05 mg/L of3,5- dichlorophenol) had respiration rates of 17.14, 34.29, and 38.77 mg 02L-lhr-1, respectively,

### ES-98-050 Page 10 ofl4 resulting in an ECso value of26.9 mg/L as calculated by regression analysis. Respiration rates for the two negative controls were 41.60 and 40.50 mg 02L-1hr-1, respectively, resulting in a mean value of41.1 mg 02L-1hr-1. The final sludge concentration ofthe second test was 2.3 g/L. The respiration rates for the 1000mg/Lreplicates, were 30.40 and 30.00 mg 02L-1hr-1, respectively, resulting 

### in inhibition values of26.6% and 27.5%. Respirationrates for the first and last negative controls were42.00 and 40.80 mg 02L-1hr-1, respectively, resulting in a mean value of41.4 mg 02L-1hr-1.
DISCUSSION This screening study was conducted based on the respiration inhibition test described in OECD Guideline 209. The actual values obtained during the experiment are reported here, togetherwith the warning that the result variability, as stated in the OECD Guideline, may indeed be unavoidable in this test. Two tests were conducted for this test substance. The first test resulted in significant foaming whenthe test substance was aerated. To stop the foaming, aeration to the test substance beaker was discontinued, while stirring was increased. Stirring did not cause foaming, but auseable reading for the test substance was not achieved. As two Negative Controls and the Positive Controls werenot affected, the 

### ECso for the Positive Control was used for the study. The remaining sludge was fed and aerated overnight. That sludge was then used to repeat the test for thetest substance, in replicates, and two Negative Coflfrols. The test substance solution was put into 2-L beakers to contain the foam. Foaming ofthe test substance, which filled the beakers, was observed throughout the 3-hourtest period. The only concentrationtested, 1000 mg/L (nominal), resulted in 26.6% and 27.5% inhibition. Therefore, the ECso is>1000 mg/L. The ECso value should be regarded merely as a guideto the likely toxicity ofthe test substance to either activated sludge sewage treatment or to waste watertreatment microorganisms, since the complex interactions occurring in the environment cannot be accurately simulated in a laboratory test. A no-observed-effect concentration (NOEC) could notbe obtainedfor this test as aneffect was observed at the single concentration tested. While some inhibition resulted at 1000 mg/L, the foaming ofthe test solution when aerated, may be a significanteffect depending upontheuse ofthe test substance. Foaming may also be a concern for waste watertreatment as such facilities are aerated.
CONCLUSION While someinhibition (26.6% & 

### 27.5%) resulted at 1000 mg/L, the foaming ofthe test solution when aerated, may be a significant effect depending upon the use ofthe test substance. Foaming may also be a concern for waste water treatment as such facilities are aerated. A no-observedeffect concentration (NOEC) could not be obtained for this test. The ECso is > 1 000 mg/L. 

# 55

### REFERENCES ES-98-050 Page 11 of 14

1. Annex V Supplement, L 133, Official Journal ofthe European Communities 

### 11_, 118 (1988). 2. OECD Guidelines for Testing ofChemicals, 1992. Activated Sludge, Respiration Inhibition Test Guideline 209. Effects onBiotic Systems. 3. ETAD (Ecological and Toxicological Association ofDyestuffs Manufacturing Industries) Recommended Method No. 103.J 

### ES-98-050 Page 12 of 14
TABLE 

### 1. Preparations ofSyntheticFeed and Positive Control Solutions

I. 

### Synthetic Feed Stock Solutions A.

### Organic Stock Solution Peptone BeefExtract Urea Sodium Chloride (NaCI) Calcium Chloride Dihydrate (CaCl2•2H20) Magnesium Sulfate Heptahydrate (MgS04•7H20) Dissolve in 500 mL 

### ofdistilled water. B. Phosphate Stock Solution Dipotassium Hydrogen Phosphate (K2HP04) Dissolve in 500 mL ofdistilled water. Amount 16.0 g 

### 11.0 g

3.0 

### g 0.7 

### g 0.4 g 

### 0.2 g



### 2.8 g
Note: This synthetic feed is a 200-fold concentrate ofthat described in the OECD Technical Report "Proposed Method for the Determination ofthe Biodegradability of Surfactants used in Synthetic Detergents" June 11, 1976, withmore dipotassium hydrogen phosphate added. This concentrate must be prepared in two separate stock solutions to preventprecipitation.
II. Positive Control Stock Solution The solution of3,5-dichlorophenol is prepared as follows: 1. 

### Dissolve 0.5 g of3,5-dichlorophenol in 10 mL ofINNaOH. 2. Dilute to approximately 30 mL with distilled water. 3. Add, while stirring, IN H2S04 to the point ofincipient precipitation- approximately 8 mL of 1 N H2S04 will be required. 4. Finally, dilute the mixture to one liter with distilled water. The pH shouldthen be in the range 7 to 8. Adjustwith IN H2S04 ifnecessary.



# 51

# fONFIDENTIAL
TABLE 2. Dissolved Oxygen WorksheetforTestSubstance ES-98-050 Page 13 of 14



# c-**~**

# ~ DISSOLVED OXYGEN WORKSHEET TEST: Respiration lnhib. Screen
BEAKERS CONC. UPPER LOWER DIST. (mg/L) VALUE VALUE (tm) (A) (A)
#1 NEG. CONT. 0 5.2 3.1 12.0 #2 TEST A 1000.00 5.1 3.2 15.0 #3 TEST B 1000.00 5.7 4.2 12.0 TEST X XXX XXX XXX TEST X XXX XXX XXX TEST X XXX XXX XXX POS. CONT. 31.25 XXX XXX XXX POS. CONT. 9.n XXX XXX XXX POS. CONT. 3.05 XXX XXX XXX #4 NEG. CONT. 0 4.7 3.0 10.0 (A) 

## =mg of oxygen from Dissolved Oxygen Meter's recordertrace (B) 

## =Respiration rate in mg of oxygen per liter per hour CHART SPEED (em/min)
4 4 4 4 4 4 4 4 4 4

Note: The Negative Controls should be within 15%

## =**~.e.,** MEAN +/- 7.5%) 41.4 +/-

Remarks: Onlyone concentration tested, in replicate, at1000 mgll. Repeat for the test article, due to previous testfailure. Positive Controlvalues from the first testwere used. Test article was aerated, foaming continued throughoutthe test period. Actual Final Sludge concentration intestbeakerswas 2.3 giL (aim 1.6 giL).



# 5S RESP. INHIB. RATE (B)
42.00 30.40 26.6% 30.00 27.5%

ERR ERR ERR ERR ERR ERR ERR ERR ERR ERR ERR ERR 40.80

3.1

# fONFIDENTIAL

TABLE 3. Dissolved Oxygen Worksheet for Positive Control ES-98-050 Page 14 of 14



# GEL No.

## 98-0024~ 

# c**--~** DISSOLVED OXYGEN WORKSHEET TEST: Respiration lnhib. Screen
BEAKERS

#1 NEG. CONT. #2 TEST TEST TEST TEST TEST #4 POS. CONT. #5 POS. CONT. #6 POS. CONT. #3 NEG. CONT. X X X X CONC. (mg/L)

0 1000.00

31.25

9.77 3.05 0 UPPER LOWER VALUE VALUE (A) (A)
5.1 2.5 See Remarl<s XXX XXX XXX XXX XXX XXX XXX XXX 6.5 5.5 6.0 4.0 4.7 2.6 5.4 2.7 (A) 

# =mg of oxygen from Dissolved Oxygen Meter's recorder trace (B) 

## =Respiration rate in mg ofoxygen per liter per hour
Note: The Negative Controls should be within 15%

## =**~.e.,** MEAN+/- 7.5%) DIST. CHAR'f- (c'm)**~SPEED** /// (em/min) / 15.6" 4 XXX 4 XXX 4 XXX 4 XXX 4 14.0 4 14.0 4 13.0 4 16.0 4

41.1 +/- RESP. RATE

(8)
41.60

ERR ERR ERR ERR ERR 17.14 34.29 38.77 40.50

3.1

Remarl<s: Due to foaming at test start, the aeration was turned off of the 1000 mg/L. The stir-barwas lef1 on. Attest end, the reading was not useable. The testwas repeated the following dayforthe test article. Actual Final Sludge concentration is test beakers was 2.2 g/L (aim 1.6g!L). INHIB.



### ERR ERR ERR 

### ERR ERR 58.2% 16.5%

5.6%

### TX-98-145 Page 1of 15

FINAL REPORT 

# fONFIDENTIAL**HAELNo.~** CIN:c==J 

### KAN: ( I 

### RAN:(--) ACUTE ORALTOXICITY STUDY INTHERAT
GUIDELINE

OECD: 401 EEC: Annex V., Test B.1 AUTHOR Kenneth P. Shepard, B.S.

TESTING FACILITY Toxicological ScienceS'Laboratory Health and EnvironmentLaboratories Eastman Kodak Company Rochester, New York 14652-6272 USA LABORATORYPROJECT 

### ID

STUDY SPONSOR Eastman KodakCompany STUDYCOMPLETION DATE August 13, 1998

### TX-98-145 Page2 of 15 

# fONFIDENTIAL

QUALITY ASSURANCE INSPECTION STATEMENT {21 CFR 58.35{B) (7), 40 CFR 792.35(B) (7), AND 40 CFR 160.35(B) (7)) STUDY: r STUDY DIRECTOR: SHEPARD,K.P. PAGE 1 ---" ACCESSION NUMBER: (_____,) 08/11/98
STUDY TYPE": ACUTE ORAL TOXICIJY 

### J1'1" 

# tfci7o DATE
THIS STUDY WAS INSPECTED BY 1 OR MORE PERSONS OF THE QUALITY ASSURANCE UNIT. WRITTEN STATUS REPORTS WERE SUBMITTED ON THE FOLLOWING DATES. INSPECTION DATES PHASE(S) INSPECTED 06/10/98 PROTOCOL APPENDIX/AMENDMENT**S~MISSION** 06/11/98 CLINICAL SIGNS AT 24 HRS. 08/11/98 FINAL REPORT REVIEW STATUS REPORT DATES

08/11/98 08/11/98

### TX-98-145 Page 3 of 15



### GOODLABORATORY PRACTICECOMPLIANCESTATE.MENT
This study was conducted according to: Annex 2, Organisation forEconomic Cooperation and Development,Guidelines 

### ' for Testing ofChemicals [C(81)30(Final)].

# ~.~~~J Kenneth P. Shepard, B.S. Study Director Month!Day/Year

### SIGNATURE PAGE

Study Director

# Do1t~.D UnitDirector, Mammalian Toxicology

John L. 

### 0' TX-98-145 

### Page 4 of 

### 15

Month/Day/Year

# A~ IZ,If98 Mont&riay/Year

Month/Day/Year

### TABLE OF CONTENTS

ABSTRACT STUDYAND TESTSUBSTANCE INFORMATION TestingFacility ProjectParticipants Sponsor Test Substance Characterization Study Dates 

### PURPOSE MATERIALSAND .METHODS Test System Husbandry Experimental Design Data Storage Statistical Procedures Protocol and Standard Operating Procedure Deviations 

### RESULTS DISCUSSION CONCLUSION REFERENCES APPENDIX TX-98-145 Page 5 of 15

Page Number 6 

### 7 7 7 7 7 7 

### 8 8 

### 8 8 

### 9 11 11 11 12 

### 14 14 14 15

### ABSTRACT

## HAELN~~ CIN: (_ 

## _> TX-98-145 Page 6 of 15 

# CONFIDENTIAL**KAN:~ RAN~**  ACUTE ORALTOXICITY STUDY IN THE RAT
An 

### acute oral toxicity study was conducted with five male and five female rats administered a single limitdose of

### 2000mg/kg ofthe test substance by gavage. The test substance was administered as a 20% 

### solution using distilled water as the vehicle. A single male was found dead on the morning following dosing. No other mortality was noted during the study. The acute oral LD50 

### for this test substance was greater than 2000 

### mg/kg for male and female rats. Abnormal clinical signs noted during the 14-day observation period were limited to diarrhea on the dayofdosing and fecal staining ofthe inguinal hair and discolored (lightbrown) feces on the day following administration ofthe test substance. No other abnormal clinical signs were evident during the study. All surviving animals gained weightduring both weeks ofthe study. Treatment-relatedchanges observed atnecropsy for the single male which died afterexposure to the test substance were limited to the presence ofthe test substance in the stomach and incomplete collapse ofthe lungs. No treatment-related changes were noted at necropsy for animals which survived to termination ofthe study. No tissue was collected for microscopic examination. Based on theresults ofthis study, the test substance was classified as, atmost, slightly toxic according to the criteria set forth by Hodge and Sterner (1949) and requires no toxicity classification as defined in the 18th Adaptation ofthe EC Classification, Packaging, and Labelling ofDangerous Substances Directive.

### TX-98-145 Page7 of15



### STUDYAND TESTSUBSTANCE INFORMATION Testing Facility Toxicological SciencesLaboratory Health and EnvironmentLaboratories Eastman Kodak Company Rochester, New York 14652-6272 

### USA 

### ProjectParticipants Study Director: Principal Investigator: Report Author: 

### Sponsor Eastman Kodak Company 

### Test Substance Characterization Test Substance Name: CAS No: HAELNo.: KAN: 

### CIN: SRID orLot No.: Physical State and Appearance: Source ofTestSubstance: Laboratory ProjectID: 

# fONFJDENTIAL

Kenneth P. Shepard, B.S. John W. Mosher, B.S. Kenneth P. Shepard, B.S.



### (- 

# )

Not available

Solid,Whtte Eastman KodakCompany 

# <__ ) Composition: Referto composition information included 

### in the notification when applicable. 

### StudyDates Study Initiation Date: Experimental Start Date: Experimental Completion Date: June 10, 1998 June 10, 1998 June 24, 

### 1998

### PURPOSE TX-98-145 Page 8 of 15

The purpose ofthe study was to determine the estimated ora] LD50 

### ofthe test substance in male and female rats and the clinical signs oftoxicity associated with a single oral dose.


### MATERIALSAND METHODS Testsystem Five male and five female Sprague-Dawleyrats (CD®(SD)BR/VAFPlus®) obtained from Charles River Kingston (Stone Ridge, NY) wererandomly assigned to the study. At initiation ofthe study, male rats were 6-7 weeks ofage and weighed 128 to 145 grams and female rats were 7-8 weeks ofage and weighed 140to 158 grams. Rats were chosen for this study because they are a common representative species for toxicity studies. The rat is one oftwo primaryrodent species recommended for use in the OECD Guideline. 

### Husbandry Housing Animals were housed in an American Association for Accreditation ofLaboratory Animal Care-accredited vivarium in accordance with

### th~Guide for the Care and Use of Laboratory Animals (National Research Council, 1996). The rats were singly housed in suspended, stainless-steel, wire mesh cages. Cages and racks were washed once a week. Absorbentpaper, used to collect excreta, was changed at least three times a week. Environmental Conditions The studyroom was maintained at 18.5-23.3

# oc and 37.9-79.4% relative humidity, except on Day 6 ofthe study when the animal room was washed and relative humidity transiently reached 96.9%. A photoperiod of 12 hours light from 6 a.m. to 6 p.m. was maintained. Acclimation Period The animals were isolated upon arrival and allowed to acclimate for a period of5 days. Animals werejudged to be healthy priorto testing.

### Husbandry, continued Feed TX-98-145 

### Page 9 of 15

Certified Rodent Diet**(PM~**

### #5002, pelleted) was available 

### adlibitum. Feed containers were cleaned weekly and refilled at least once a week. No known contaminants which would interfere with the outcome ofthis study werepresent in the feed. Analyses offeed are maintained on file within the testing laboratory.

Waterwas available

### adlibitum through an automatic watering system. The source ofthe water was the local public watersystem. There have been no contaminants identified in periodic water analyses that would be expected to interfere with the conduct ofthe study. Semiannual analyses ofwater are maintained on file within the testing laboratory. Identification Upon arrival, aU rats were identified by uniquely-numbered metal eartags. During randomization, study-specific animal numbers were assigned to each animal. Cage cards contained the study-specific animal number and the eartag number. 

### ExperimentalDesign Test Procedures This study was conducted according to the Organisation for Economic Cooperation and Development (OECD) Guidelines for Testing ofChemicals Guideline: 401, Acute Oral**Toxicity~** 

### and European Economic Community (EEC): Annex V., Test B.l ,Acute Toxicity (Oral). Randomization The procedure for including animals in the study was to randomly select and assign animals from the same shipmentto the study. Randomization was done bycomputergenerated lists. After assignmentofanimals to the study, the body weights were determined to ensure that variation in individual body weights did not exceed 20% ofthe mean weight for each sex. Determination ofDose Levels A 

### limitdose of2000mgofthe test substance/kg body weight was selected as the dose level for the oral toxicity study.

### ExperimentalDesign, continued Preparation ofTest Substancein the Vehicle TX-98-145 Page 10 of 15

The test substance, a solid, was administered as a 20% solution using distilled wateras the vehicle. Test Substance Exposure A single dose ofthe test substance was administered by gavage to animals that had been fasted overnight. Distribution ofAnimals TABLE 1 

### Animal Distribution Dose Level NumberOf Animal Numbers Animals Males 

# I Females 2000mg/kg 5 Males & 

### 5 Females 391

- 395 396-400 BodyWeights Body weights were collected on Days 0 (prior to treatment), 7, and 14. Clinical Observations Animals were observed three times on the day ofdosing (Day 0), and once each day thereafterfor the duration ofthe experiment. Observations included, but were not limited to, examination ofthe hair, skin, eyes, mucous membranes, motoractivity, feces, urine, respiratory system, circulatory system, autonomic nervous system,central nervous system, and behaviorpatterns. Necropsy Any animal that died during the study was necropsied as soon as possible. All surviving animals were euthanatized and necropsied at the completion ofthe 14-day observation period.

### Data Storage TX-98-145 Page II of 15

Thefinal report, data sheets, all nonperishable raw data, and an aliquot ofthe test substance have been stored in the testing facility archive managed under GLP-mandated conditions. 

### Statistical Procedures No statistical procedures were required during the study. No dose/mortalitycurve was constructed since graphs become statistically useful only with the use oflarge numbers ofanimals and dose groups. 

### Protocol and Standard OperatingProcedureDeviations The were no SOPor protocol deviations during the study.



# 70

### Mortality 

### RESULTS TX-98-145 Page 12 of 15

Thedose level, the numberofanimals dosed, and the numberand time ofdeaths are 

### listed in Table 2. 

### TABLE2 Mortality Table Dose (mglkg) NumberofRats Exposed NumberofDeaths

2000 5 Males, 

### 5 Females I 

### Male 

### Time ofDeath

Within 24 

### Hours 

### LD50 

### for malerats: LD50 

### for female rats: 

### > 2000 mg/kg (95% C.I. =No Range Calculable) 

### > 2000 mg/kg (95% C.l. =NoRange Calculable) Clinical Signs Thetime ofeach observation and the numberof**anim~** 

### involved are 

### listed in Table 

### 3. TABLE3 Table OfClinical Observations Dose Time Clinical Signs NumberofAnimals (mglkg) Affected

2000 DayO Appeared ClinicallyNormal 4/5 Males, 3/5 Females Diarrhea 115 Males, 215 

### Females 2000 Day 1 Found Dead 115 Males Discolored (Light Brown) Feces 4/4Males, 5/5 Females

Fecal Staining ofInguinal Hair 1/4Males, 5/5 Females 2000 Days 2 to 14 Appeared Clinically Normal 4/4Males, 5/5 Females WeightGain All surviving animals gained weight during both weeks ofthe study. 

# 11

### Individual Body Weights The individual body weights are listed in Table4.


### TABLE4 TX-98-145 Page 13 of 15



### Table OfIndividualBody Weights (grams) 

# I

Dose (mglkg)

# I AnimalNumber DayO Day7 Day 14 MALE RATS 2000 391 130 207 276 2000 392 143 222 280 2000 393 144 223 285 2000 394 128 200 246 2000 395 145 Found Dead Day 1 

### FEMALERATS 

# - 2000 396 158 211 236 2000 397 153 204 219 2000 398 140 

### 184 197 2000 399 152 209 234 2000 400 

### 147 203 222
Necropsy Findings No treatment-relatedchanges wereobserved at necropsy for animals surviving to termination of the study. Forthe single male which died within 24hours ofdosing (Rat 395), changes noted at necropsy were limited to the presence ofthe test substance in the stomach and incomplete collapse ofthe lungs. The incomplete collapse ofthe lungs when the thoracic cavity was opened during necropsy was considered an incidental fmding. In

### the absence ofsignificant gross organ lesions, no tissue was collected formicroscopic examination. A detailed record ofthe tissues examined is presented in computer-generated tables which are included in the Appendix.

# 1~

### DISCUSSION TX-98-145 Page 14of15

This acute oral toxicity study was conducted with five male and five female rats administered a single limit dose of2000mg/kg ofthe test substance administered as a 20% solution in distilled water. A single male was found dead on the morning following dosing. No othermortality was noted during the study. Abnormal clinical signs noted during the 14-day observation period were limited to diarrhea on the day ofdosing and fecal staining ofthe inguinal hair and discolored (light brown) feces on the day following administration ofthe test substance. No other abnormal clinical signs were evident during the study. All surviving animals gained weightduring both weeks ofthe study. Treatment-related changes observed at necropsy for the singlemale which died afterexposureto the test substance were limited to the presence ofthe test substance in the stomach and incomplete collapse ofthe lungs. No treatment-related changes were noted at necropsy for animals which survived to termination ofthe study. No tissue was collected for microscopic examination. The acute oral LD50 

### for this test substance was greater than 2000 mg/kg for male and female rats.


### CONCLUSION Based on the oral LD5o

### for male and female rats, the test substance was classified as, at most, slightly toxic according to the criteria setforth by Hod-ge and Sterner (1949) and requires no toxicity classification as defined in the 18th Adaptation ofthe EC Classification, Packaging, and Labelling ofDangerous Substances Directive.


### REFERENCES Hodge, H.C. and Sterner, J.H. (1949). Tabulation oftoxicity classes. 

### Am. Indust. Hyg. 

### Quart., 10,93-96. National Research Council (1996). 

### Guidefor the Care and Use of LaboratoryAnimals. National Academy Press. Washington, D.C.


# 13

# APPENDIX



# 74 TX-98-145 

### Page I5 of 15SUMMARY GROSS PATHOLOGY INCIDENCE TABLE

- MALE RATS GROUP TRACHEA LUNGS INCOMPLETE COLLAPSE OF THE LUNGS THYMUS HEART ESOPHAGUS STOMACH TEST SUBSTANCE PRESENT DUODENUM JEJUNUM ILEUM CECUM COLON RECTUM LIVER KIDNEYS URINARY BLADDER PITUITARY GLAND ADRENALS PANCREAS, NOS THYROID GLANDS PARATHYROID GLANDS SPLEEN MESENTERIC LYMPH NODES BONE MARROW BRAIN EYES SALIVARY GLANDS ADIPOSE TISSUE SKIN, NOS HAIR ACCESSORY SEX ORGANS (MALE) EPIDIDYMIDES TESTES 2000 MG/KG 5 5 1 5 5 5 5 1 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 

### TX-98-145 

### Appendix Page l of4

NUMBERS REPRESENT NUMBER OF TISSUES EXAMINED, OR IN THE CASE OF ABNORMAL FINDINGS, THE NUMBER OF TISSUES WITH EACH ABNORMALITYGROUP TRACHEA LUNGS THYMUS HEART ESOPHAGUS STOMACH DUODENUM JEJUNUM ILEUM CECUM COLON RECTUM LIVER KIDNEYS URINARY BLADDER PITUITARY GLAND ADRENALS PANCREAS, NOS THYROID GLA.t'IDS PARATHYROID GLANDS SPLEEN SUMMARY GROSS PATHOLOGY INCIDENCE TABLE

- FEMALE RATS 2000 MG/KG 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5
MESENTERIC LYMPH NODES 5 5 BONE MARROW BRAIN EYES SALIVARY GLANDS ADIPOSE TISSUE SKIN, NOS HAIR FALLOPIAN TUBES VAGINA UTERUS OVARIES CERVIX UTERI 5 5 5 5 5 5 5 5 5 5 5 5 

### TX-98-145 Appendix Page 2 of4

NUMBERS REPRESENT NUMBER OF TISSUES EXAMINED, OR IN THE CASE OF ABNORMAL FINDINGS, THE NUMBER OF TISSUES WITH EACH ABNORMALITY 

# 70

### TX-98-145 

### Appendix Page 3 of4

INDIVIDUAL ANIMAL GROSS PATHOLOGY INCIDENCE TABLE

- MALE RATS ANIMAL # DAYS ON TEST TRACHEA LUNGS INCOMPLETE COLLAPSE THYMUS HEART ESOPHAGUS STOMACH

TEST SUBSTANCE PRESENT DUODENUM JEJUNUM ILEUM CECUM COLON RECTUM LIVER KIDNEYS lJRINARY BLADDER PITUITARY GLAND ADRENALS PANCREAS, NOS THYROID GLANDS PARATHYROID GLANDS SPLEEN MESENTERIC LYMPH NODES BONE MARROW BRAIN EYES SALIVARY GLANDS ADIPOSE TISSUE SKIN, NOS HAIR ACCESSORY SEX ORGANS (MALE) EPIDIDYMIDES TESTES 391 392 393 394 395 14 14 14 14 1 X X X X X X X X X p X X X X X X X X X X X X X X X X X X X p X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X KEY: N-NORMAL AND TISSUE COLLECTED FOR HISTOPATHOLOGY, 1-MINIMAL, 2-MINOR, 3-MODERATE, 4-SEVERE, P-PRESENT, A-ABSENT, *-SEE COMMENT REPORT, X=NORMAL BUT NOT COLLECTED 

# 77

### TX-98-145 

### Appendix Page 4 of4

)
INDIVIDUAL ANIMAL GROSS PATHOLOGY INCIDENCE TABLE -FEMALE RATS ANIMAL # DAYS ON TEST TRACHEA LUNGS THYMUS HEART ESOPHAGUS STOMACH DUODENUM JEJUNUM ILEUM CECUM COLON RECTUM LIVER KIDNEYS URINARY BLADDER PITUITARY GLAND ADRENALS PANCREAS, NOS THYROID GLANDS PARATHYROID GLANDS SPLEEN MESENTERIC LYMPH NODES BONE MARROW BRAIN EYES SALIVARY GLANDS ADIPOSE TISSUE SKIN, NOS HAIR FALLOPIAN TUBES VAGINA UTERUS OVARIES CERVIX UTERI 396 397 398 399 400 14 14 14 14 14 X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X. X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X A X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X KEY: N-NORMAL AND TISSUE COLLECTED FOR HISTOPATHOLOGY, 1-MINIMAL, 2-MINOR, 3-MODERATE, 4-SEVERE, P-PRESENT, A-ABSENT, *-SEE COMMENT REPORT, X=NORMAL BUT NOT COLLECTED

# CONFIDENTIAL
FINALREPORT



### PURITY DETERMINATION AUTHOR 

### Tracey L. Sanford
TESTINGFACILITY Environmental Analytical Services Chemicals Quality Services Division Manufacturing QualityAssurance Organization Eastman Kodak Company Rochester, New York 14652-6276 USA
STIJDY SPONSOR Eastman Kodak Company
REPORTNo: L8329-PKV
STIJDY COMPLETIONDATE 

### July 16, 1998


# 79• t 

# CONFIDENTii\L

ANALYTICAL QUALITY ASSURANCE INSPECTION STATDU:NT (CrR 58.35(8)(7) 792.35(8)(7) 160.35(8)(7)) STUDY: STUDY DIRECTOR: ISAAC3,8 ANALYTICAL DIRECTOR: CQS JOB lroMBER: STUDY TYPE:

THE FOLLOWING PRA.SES Of' THIS STUDY WERE INSPECT!.D BY ONE OR MORE PERSONS OF THE QUALITY ASSURANCE U}IIT OH THE DATES LISTED BELOW. WRITTEN STATUS REPORTS WERE SUBMITTED TO THE STUDY DIRECTOR AND JI.PPROPJ'UA!'l: MI'.NAGEXDIT.
INSPECT REQUEST PHASE(S) STATUS REPORT

DATES HUMBER INSPECTED DATES



### ------- ------- 

## --------- ----------- 06/23/98 PROTOCOL SUBMISSION 06/23/98 CRI, PUR 06/23/98 PHASE INSPECTION 06/23/98 CRI, PUR 07/16/98 TEST REPORT INSPECTIOH 07/16/98 CRI, PUR



### Page 2 of19 

# 8D L8329-PKY ' 

# )

)



# )! 

# '**GOODLABORATORYPRACTICECO~L~CESTATEMENT** 

### This studywas conducted accordingto:
Uruted States Food and Drug Administration, 

### Good Laboratory Practice for Nonclinical Laboratory Studjes, 21 CFRPart 58; United States Environmental Protection Agency, Toxic Substances Control Act, Good LaboratoryPractice Standards, 40 CFRPart 792; Annex 2, Organization for Economic Cooperation and Development, Guidelines for the Testing ofChemicals (C(81)30(Fina1)).

# DP=#~~ Beth Isaacs

# ~ StudyDirector

Page 3 of 19 

# 8/

# ~ llo, 1116' nth/Day/Year

L8329-PKY

### Report Author

# ~~ Beth Isaacs StudyDirector 

### SIGNATURE PAGE 

## )

ontb!Day/Year



# U Month!Day/Year



### L8329-PKV 

### )

# l TABLE OFCONTENTS LIST OFFIGURES ABSTRACT STUDYAND TEST SUBSTANCE INFORMATION TestingFacility



### PURPOSE Sponsor SponsorRepresentative StudyDates Project Participants Test Substance Characterization Test Substance Storage
1\t>\.

### TERIALS AND l\IETHODS

RESULTS PurityDetermination Procedure Weight Percent WaterDetennination Procedure Weight Percent VolatilesDetermination Procedure Weight Percent Methanol and Acetone Determination Procedure Instrument Conditions Calculations Protocol and Standard OperatingProcedureDeviations Data Storage and Record Retention Weight Percent 

### Purity Weight Percent Water Weight Percent Volatiles Weight Percent Methanol and Acetone 

### CALCULATIONS DISCUSSION CONCLUSIONS

Page 5 of 19 

# 83 Page 6 7 

### 8 8 8 

### 8 

### 8 9 9 

### 9 9 

### 9 9 10 10 10 10 11 12 12 

### 12 12 12 12 

### 13 13 14 14



### L8329-?KV

# ) LIST OFFIGURES I. Titration Curve ofTestSubstance 15 II. Titration Curve ofBlankSolvent 16 

### ill. Chromatogram ofBlankAcetonitrile 17 IV. 

### ChromatogramofMethanol and Acetone Standard 

### in Acetonitrile 18 V. 

### ChromatogramofTest Substance 

### inAcetonitrile 19



### Page 6 of19 L8329-PY:V 

### ) J

# CONFIDENTIAL c )

ABSTRACf The purity ofthe test substance was analyzed 

### in triplicate for weight percent purity using potentiometric titration with 0.1 N perchloric acid (HC104). 

### The mean weight percent purity was determined to be 99.8 with a standard deviation of0.58. The test substance was analyzed 

### in triplicate for weight percent water using an AQUAST AR13 

### V5000 Karl Fischer titrator. The mean weight percent water was 0.69 with a standard deviation of0.018. The test substance was analyzed in triplicate for weight percent volatiles using the Denver IR-100 moisture analyzer. The 

### mean weight percent volatiles at 105 

### oc was 0.88 with a standard deviation of0.092. The test substance was analyzed for weight percent methanol and acetone using gas chromatography with flame ionization detection. No methanol or acetone peaks were detected above the instrument detection limit 

### in the test substance
..The weight percent methanol and acetone are reported as less than the respective method detection 

### lirrllts of 0.01 and 0.001 weight percent. The 0.19 weight percent volatiles unaccounted for were not identified.

Page 7

### of 19 L8329-PKV

### STUDYAND TEST SUBSTANCE**INFO~IATION** 

### TestingFacility Environmental Analytical Services Chemicals Quality 

### Services Division Eastman Kodak Company Rochester, NewYork 14652-6276 USA 

### Sponsor Eastman Kodak Company Rochester, NewYork 14652 USA 

### SponsorRepresentative Julie Byrne Eastman Kodak Company Rochester, New York 14652 

### USA 

### Study Dates 

### Study Start Date: 

### Purity: Experimental Start Date: Experimental Completion Date: WeightPercent Water: Experimental Start Date: Experimental Completion Date: Weight Percent Volatiles: Experimental Start Date: Experimental Completion Date: June 22, 

### 1998
June 22, 

### 1998 June 

### 23, 1998 July 

### 6, 1998 July 

### 6, 1998 July 

### 6, 1998 July 

### 6, 1998 WeightPercent Methanol and 

### Acetone: Experimental Start Date: July 9, 1998 Experimental Completion Date: July 10, 

### 1998

Page 8 of19 

## )

# ( Project Participants StudyDirector: Principal Investigators:
Report Author: 

### Test Substance Characterization

Received into Laboratory


### Test Substance Storage 

# CONFIDENTIAL

Beth 

### Isaacs Tracey Sanford Beth Isaacs GinaLynch 

### Sarah McCullough Tracey Sanford

May 27, 1998

The test substance was stored at room temperature in a locked cabinet before and after each analysis wasperformed.


### PURPOSE The purpose ofthis study was to determine the weight percent purity, weight percent water, and weightpercent volatiles.


### MATERIALSAND METHODS PurityDetermination Procedure Titration: Approximately 0.25 grams ofthe test substance was weighed into a titration vessel. The test substance was dissolved in I0 

### mL ofacetic acid and then 200 

### rnL acetic anhydride was added. The test substance was analyzed in triplicate by potentiometric titration.

Page 9 

### of 19 

### L8329-PKV 

# 81

### \Veight PercentWater Determination Procedure Approximately 0.2 grams of the test substance was weighed, transferred to an AQUASTAR® V5000 volumetric titrator, and mixed with AQUASTAR® Methanol. The mixnrre was stirred 

### until the test substance was dissolved, then titrated. WeightPercentVolatiles Determination Procedure Approximately 

### 2 grams 

### ofthe test substance was placed into a pre-weighed aluminum dish. The dish with the test substance was placed on the moisture analyzer. Theweight percent volatiles of the test substance at 105 oc was calculated using the Denver IR-100 Moisture Analyzer. The initial weights, 

### final weights, dryingtemperatures and percent volatiles results were recorded. \Veight PercentMethanol and AcetoneDetermination Procedure Approximately 1 gram 

### ofthe test substance was weighed into a 100-mL volumetric flask. The flask was filled to volume with acetonitrile, 

### and analyzed using 

### GC/FID. A stock solution wasprepared by adding approximately one gram of both methanol and acetone to a 1 

### 00-mL volumetric flask ana diluting to volume with acetonitrile. This stock was diluted to yield concentrationsranging from 0.1 to 1000 mg!L and analyzed using GC/FID. Instrument Conditions TitrationTest Conditions: Instrument: Indicating Electrode: Reference Electrode: Metrohm 670 Titrator CorningpH Orion DoubleJunction filled with 10%TMAC (tetramethylammoniumchloride) Titrant: Dosimat Rate: 0.1025 

### N HCI04 

### (perchloric acid) 

### in HOAC (glacial acetic acid) 1.0mL/rninute Buret Volume: 

### lOmL Weight Percent WaterDetermination: Instrument: AQUASTAR® V5000, VolumetricTitrator Titrant: AQUASTAR® Comp-2, Karl FischerReagent Titrant Factor 2.4575 mg water/mL titrant 

### Solvent: AQUAST AR® Methanol Weight Percent Volatiles Determination: Instrument: DenverInstrument IR-100 Moisture Analyzer TestTemperature: 105 oc Slope: 0.05%@ 1

### minute

Page10ofl9 L8329-PKV 

# )

### Weight Percent Methanol and Acetone Determination: The samples were analyzedbyGCIFID using the following instrument conditions: Instrument: Column: Injection Size: Initial Head Pressure: Canier: DetectorTemp.: InjectorTemp.: Oven Conclitions: Initial Temp (OC)



### 35 

### Calculations Weight Percent Purity: HewlettPackard Model 5890 GCIFID DB Wax, 30**~** 

### 0.32 mm i.d., 0.25**~rn** 

### film thickness 1**~L** 

### split injection 

### 7.5 psig Helium 300

# oc 250

# oc Hold Time Rate (°C/min.) Final Temp. (°C) 

### (min.) 2 10 

## . 200 Final Time 

### (min.) 1

The weight percent purity of the test substance was determined based on the number of test substance rnilliequivalents titrated with 0.1025 

### N HC104 . 

### Weight Percent Water: The weight percent water was calculated by multiplying the factor oftitrant (mg water/mL) by the quantity oftitrant used for the titration ofthe sample 

### (rnL), dividing by the sample weight (mg), and multiplying the quotient by 100. Calculations were performed using 

### an AQUASTAR® V5000 volumetric titrator. Weight Percent Volatiles: The weight percent volatiles ofthe test substance was calculated by comparing the weight ofthe test substance (grams) at 

### timed intervals (seconds) during a 

### drying process to the initial test substance weight 

### (grams). The final weight ofthe test substance was subtracted from the initial weight ofthe test substance, and the result was divided by the initial weight ofthe test substance and multiplied by 100. Calculations were performed using a Denver Instnunent IR-100 Moisture Analyzer. Weight Percent Methanol and Acetone: The estimated method detection limit ofmethanol and acetone was calculated by multiplying the instrument detection limit by 100 

### rnL, dividingbythe amount oftest substance in micrograms, and multiplying this quotientby 100percent.
Page 

### 11 of 19 L8329-PKV 

# 89

### Protocol and Standard Operating Procedure Deviations Therewere no deviations noted. Data Storage and Record Retention All original protocols, raw data, 

### and 

### reports will 

### be stored for 

### at least ten years by the Chemicals Quality Services**Divisio~** 

### Building 320 ofthe Eastman Kodak Company, Kodak Park, Rochester, NewYork 14652-6276. 

### RESULTS Weight Percent Purity The results ofthe purity analysis by potentiometric titration were as follows: Replicate 

# . Weight Percent Purity (wt 

### %) 

### #1 100.4 

### #2 99.76 #3 99.27 Mean= 99.8 

# I Standard deviation = 0.58 

# ICoefficient ofVariation(%)= 0.581 Weight PercentWater The results ofthe weight percentwater analyses were: Replicate Weight Percent Water (wt 

### %) 

### #1 0.7116 #2 0.6817 #3 0.6798 J\Iean = 0.69 

# t Standard deviation= 0.018 

# I Coefficient ofVariation (%) = 2.6 Weight Percent Volatiles The results ofthe weight percent volatiles analyses were: Replicate Weight Percent Volatiles (wt %) 

### #I 0.78 #2 0.96 #3 0.90 Mean= 0.88 

# I Standard deviation= 0.092 

# I Coefficient ofVariation (%)= 10.5

Page 12 ofl9 

### 18329-PKV 

# go

. 

### '

,.

# ( Weight Percent Methanol and Acetone The results ofthe weight percent methanol and acetone are reported as less than the estimated method detection limits since no peaks for either solvent were detected above the instrument detection linllt 

### in the test substance chromatogram. The weight percent methanol and acetone 

### in the test substancewas determined to be less than 0.01 and 0.001, respectively.


### CALCULATIONS Weight Percent**Purity(~/o)** 

### =

# M (N)**(W~** 

### x 100 

# w. where, V =volume oftitrant for sample (mL) minus the volume oftitrant for blank (mL) 

### minus the volume oftitrant for the impurity (mL) N =normality oftitrant (milliequivalents/mL) = 0.1025 meq/mL 

### HC104 

### Weq 

### =milliequivalent weight oftest substance= 442 mg/meq W, = weight ofsample (mg) e.g. Replicate 1

Weight% Purity= (6.090mL- 0.020mL- 0.358mL) (0.1025 meq/mL) (442 mg!meg) X 100 257.7mg = 100.42 wt% Weight Percent Water (wt%) = F1 x titer x I00 Size where, Fl =FactorofTitrant (mg water/mL) titer= Quantity ofreagent used for titration (mL) 

### Size= Sample weight (mg) e.g. Replicate I Weight Percent Water= 2.4575 x 0.6I5 x 100 = 0.7II6 wt% 212.4

Page 13 of 19 L8329-PKVWeightPercent Volatiles (wfl/o)

## =

e.g. Replicate 

### 1 initial weight ofsample(g)- final weightofsample(g) initialweight ofsample(g) 2.055-2.039 X 100

## =0.78**~/o** 2.055 WeightPercentMethanol and Acetone**(~/o)** = X 100

instrument detection 

### limit (ug/mL) x 100

### rnL x 100% amount test substance (ug) e.g. Methanol Weight Percent Methanol= 0.5 x 100 x 100 = 0.005 wt% 

## = 0.01 wt% 1.005g X 1,000,000ug/g
DISCUSSION The test substance was analyzed for purity on June 23, 1998 using potentiometric titration with 0.1 N 

### HC104• The mean weight percent ofthe test substance was 99.8. A titration curve ofthe test substance solution is sho"Ml 

### in Figure I (page 15 of 19). A titration curve of the blank solvent is shown in Figure II (page 16of 19). ) The test substance was analyzed 

### in triplicate for weight percent water on an AQUASTAR® VSOOO Karl Fischertitrator. The meanweightpercent waterwas 0.69. The test substance was analyzed in triplicate at 105

# oc for weight percent volatiles using a Denver InstrumentIR-100moisture analyzer. Theweightpercentvolatiles at 105 °Cwas 0.88. The test substance was analyzed for weight percent methanol and acetone on July 9, 1998 using GC/FID. The weight percent methanol and acetone was less than 0.01 and less than 0.001, respectively. The remaining 0.19 weight percent volatiles were not identified.
CONCLUSION The purity ofthe test substance was 99.8 weight percent using potentiometric titration. The mean weight percent water was determined to be 0.69. The mean weight percent volatiles at 105 °C was determined to be 0.88. The weight percent methanol and acetone was less than 0.01 and less than 0.001, respectively. The remaining 0.19 weight percent volatiles were not identified.

Page 14 of19 LS329 PKY 

# )

# ( FlGUREI TITRATION CURVE OFTESTSUBSTANCE

Millivolts



### Page15ofl9 600 I 6613 I 720 I 780 8iu I



### L8329-PKV

### FIGURED TITRATION CURVE OFBLANKSOLVENT 

# (**~** ...).1**~** ....**~** 6ee I 660 I

Millivolts



### Page 16 of 19 729 I ?Sa I s-.e I 900 I



### L8329-PKV 

# )

# (

n**~~** 103.0

.: I·**~**



### - ,-, I. - . ll

,. 

### FIGURE 

### ill CHROMATOGRAM OF BLANKACETONITRILE



# .

R**.~** ' 

### '**~** ' 1J. ll 1**~** __; 14 . } 

### :·. u J. _, ....**~**



### Page 17 ofl9 

# 95 ..----
1b.,, 18. 

### c F:T



### L8329-PKV

### ) FIGURE IV CHROMATOGRAM OFMETHANOLAND ACETONE STANDARDIN ACETONTinULE J



### 108.0

! l4
.:J

/HeJ:i 1

### o

## >o

# L_IlLJL_jl
_

# _I_.P.)....---~-~-----------l )

=· ,li 4.0 

### 6.0 8. II i4. 0 It.0 12. ·I -·



### Page 18 of19 L8329-PKV 

# )

# (

rr**~** 103.0

• I_ L • !I

J.IJ 

### FIGURE V CHRO.MATOGRAM OF TESTSUBSTANCE IN ACETONITRILE

l

' I -. l 

### [.)._

4.0 

### -**~**

8. 0 IJ. 0**~** 14.0 16. 0 18. I**~::**



### Page 19 of 19 L8329-PKV

# c**CONFIDENTIA~** FINALREPORT

ULTRAVIOLETNISIBLELIGHT SPECTROSCOPY


### GUIDELINE OECD, Section 1, No. 101


### AUTHOR MarkA. Dulaney
TESTING FACILITY Environmental Analytical Services Chemicals 

### Quality Services Division Manufacturing Quality Assurance Organization Eastman Kodak Company Rochester, NewYork 14652-6276 

## USA
STUDY SPONSOR Eastman Kodak Company ReportNo.: L8329-SUV 

### STUDY COMPLETION DATE July 

## 1{1998

# CONFIDENTIAL

ANALYTICAL QUM.IT'Y**ASSUAANC~** INSPECTION**STAT~** (CFR S8.3S(B) (7) 792.3S(B) (7) l60.3S(B) (7)) STUDY: STUDY DIRECTOR: WU:
.. szcz-a,L ANAL'iTI CAL DI REC'l:OR: CQS JOB NUMBER: STUDY TY.PE: W-VlS ABSORPTION SPECTRA (AUDITOR, QUALITY ASSURANCE UNIT)

THE FOLLOWING PHASES OF THIS STUDY WERE INSPEC!E.D BY ONE OR MORE**P~ONS** OF THE QUALITY ASSURANCE UNIT OH THE OATES LISTED BI!:.LOW. WRITTDI STATUS REPORTS lfE.RL SUBMITTED TO THE STUDY DIRECTOR AND APPROPRIATE K}V{AGEXENT.
INSPECT

DATES 06/10/98
06/10/98
07/14/98 REQUEST NUMBER PHA.SE(S) INSPECTED PROTOCOL SUBMISSION CRI,lJVV PHASE DISPEC!ION CRI,lJVV TEST REP<>RT INSPECTION CRI,W



### Page 2 of17 STATUS REPORT DATES 06/10/98
06/10/98
07/H/98



### L8329-SUV 

# )**GOODLABORATORYPRACTICECO~LUNCESTATEMENT** 

### ( 7llis :>i:uJy 

### was conducted according

### to:



# (

(_ United States 

### Food and Drug Administration, Good Laboratory Practice for Nonclinical Laboratory Studies,

### 21 CFRPart 58; United States Environmental Protection Agency, Toxic Substance Control Act, Good LaboratoryPractice 

### Standards, 40 CFRPart 792.; Annex 

### 2 ofthe Organization for Economic Cooperation and Development, Guidelines for Testing ofChemicals [C(81)30(Final)].

Study

### Director

Page 3 of 

### 17 

### L8329-SUV 

# /60

## SIGNATURE PAGE

,

•**M~nth!Day/Y**ear

StudyDirector



## \ ! 

### Page 4 of 17 

# ID

# I L8329-SUV

### TABLE OFCONTENTS 

# ( Page TABLE OFFIGURES 6 

### ABSTRACT 7 STUDYAND TESTSVBSTANCE INFORMATION 8 Testing Facility 8 Sponsor 8 SponsorRepresentative 8 Study Dates 

### 8 Project Participants 8 Test Substance Characterization 8 Test SubstanceStorage 

### 9 PURPOSE 

### 9 MATERIALS AND METHODS 9 Test Solution Preparation and Test Conditions 9 Test Monitoring IO Instrument Conctitions IO Calculations 10 Protocol and Standard OperatingProcedureDeviations II Data Storage and Record Retention I1 

# ( RESULTS 1I Neutral Water 1I Acictic Water 1I Basic Water II pH ofTest Solutions 12 CALCULATIONS 12 Equation for Converting mg!L to moleJL 12 Equation for MolarAbsorption Coefficient 12 Equation for Bandwidth 12 Representative Calculations 12 DISCUSSION 13 CONCLUSION 13 REFERENCES 13

( ' 

### Page 5 of17 

## Jo?..., L8329-SUV

### TABLE OF FIGURES 

# ' Figure 

### 1. Test Substance 

### inNeutral Water 

### 14 Figure2. Test Substance

### in Acidic Water


### .. 15 Figure3. TestSubstance 

### inBasic Water 

### 16 Figure

### 4. Holmium Oxide

- (SRM 2034) 

### 17

)



# ) Page 6 of 17 

# /03 L8329-SUV

# (

( 

# CONFIDENTIAL

ULTRAVlOLETNISIBLELIGHTSPECTROSCOPY
ABSTRACT
The ultraviolet/visible (UVNis) light spectroscopy ofthe test substancewas studied in conformance with Annex 2 ofthe OECD Guidelines for Testing ofChoocals (C(81)30(Fina1)), as outlined by OECD Gilldeline 101. The test substance was found to be readily soluble in water (water refers to rugh purity waterwruch is used throughout the remainder ofthe report). Three working solutions
were prepared by diluting the test substance stock solution into neutral water, acidic water, and basic water. The spectra ofthe test substance in the three matrices were obtained. The absorbance maxima from the spectra were used to determine bandwidths and molar absorption coefficients for the three matrices. The results ofthe ultraviolet/visible light spectra indicate that the test substance maybe susceptible to photocherrUcal degradation.

Page 7 of 17 

### L8329-SUV

# . CONFIDENTIAL STUDYAND TESTSUBSTANCE INFORMATION Testing Facility Environmental 

### Analytical Services Cbemicals Quality ServicesDivision 

### Manufacturing Qua]jtyAssurance Organization Eastman 

### Kodak Company Rochester, New York 14652-6276

- 

## USA Sponsor: Eastman 

### Kodak Company SponsorRepresentative Julie Byrne 

### Eastman Kodak Company 

### Rochester, New York 14652-6267 Study 

### Dates Study Start Date: Experiment Start Date: Experiment Completion 

### Date: Project Participants Study Director 

### Principal Investigator Repon Author


### Test Substance Characterization

Received into Laboratory: June 

### 10, 1998 June 

### 11, 

### 1998 June 

### 11,1998


### Lori J. Wieszczyk Mark 

### A. Dulaney Mark

### A. Dulaney



### May 27, 1998



### Page 8 of 17 

# Jot; L8329-SUV 

### )

### Test Substance Storage ( Thetest 

### substance was stored atroom temperaturein a locked cabinetbefore and after

### use.



# (



# ( PURPOSE The purpose ofthis test was 

### to determine the 

### UVNis absorption spectrum ofthe test substance. The information obtained was used 

### to calculate bandwidths and molar absorption coefficients. These properties characterize the energy absorbed at various wavelength regions where the test substance maybesusceptibleto photochemical degradation. 

### MATERIALS AND METHODS Test Solution Preparation and 

### Test Conditions A test substance stock solution was prepared by diluting the test substance into water. 

### Three working solutions werepreparedbydiluting the test substance stock solution into neutral, acidic and basic water. The 

### acidic water diluting solvent was prepared by adding 20.0 

### mL ofone 

### (1) molar hydrochloric acid solution to a 200-mL volumetric 

### flask and diluting to volume with water. The 

### basic water diluting solvent was prepared by adding 20.0 

### mL of one (1) molar sodium hydroxide to a 200-m.L volumetric flask and diluting

### to volume withwater. The

### neutralwatersolvent 

### used for the analysis waspurified water. The 

### stock solution was prepared by weighing 0.2028 

### grams ofthe test substance into a 100-mL
· volumetric flask and diluting to volumewithpurified water.

The

### test substance representations were prepared using aliquots ofthe test substance stock solution to generate three solutions that, when 

### analyzed, yielded spectra that bad 

### at least one peak with an absorbance unit between 0.5 and 1.5. The neutral test substance representation was prepared by diluting 200 )lL of the stock solution 

### to 25 milliliters with the neutral purified water, 

### final concentration of 16.22 rng!L. The acidic test substance representation was prepared by diluting 400 )lL ofthe stock solution to 25 milliliters with the acidic water, 

### final concentration of32.448 mg!L. Thebasic test substance representation 

### was prepared by diluting 2000 

### )lL ofthe stock solution to 25 milliliters with the basic water, 

### final concentration of 162.24 mg!L. The acidic 

### and basic water diluting solvents were used as the background correction and blank solutions for the acidic and basic test substance solutions, respectively. Waterwas used as the background correction and blank solution for the neutral test substance solution.

Page 9 of 17 

# /Dlo L8329-SUV

### TestMonitoring The studywas carried out 

### at 22.3 

### oc_ Instrument Conditions The solutionswere analyzedusingthe following conditions: Instrurn

### ent: Data CollectionMode: ScanRange: Scan Speed: Slit: DataInterval: Cells: PerkinElmerLambda40Spectrophotometer with Perkin ElmerUV 

### WmLab® software Absorbance WavelengthMax. 900nanometers (nm) Wavelength

### Min. 

### I90

### nm 480 nm/minute 2.0nm 

### I 

### nm 1.0 

### centimeter(em) 

### quartz 

## ,

A weekly holmium oxide standard was analyzed to 

### ensure the instrument was performing properly. See Figure 4 

### (page I 7 

### of I7) 

### for the ultraviolet/visible light spectrum of the holmium oxide standard. Calculations The concentration of the test substance 

### in mole!L was calculated by converting the units of concentration from mg!L to 

### giL and then converting to mole/Lby relating 

### this concentration to the molecular weight ofthe test 

### substance. The calculations were performed using 

### a Microsoft® Excel spreadsheet The molar absorption coefficient was calculated at each wavelength where a maximum absorbance was obtained for the test substance. The molar absorption coefficient was expressed in Llmole·cm. The calculations wereperformed using a

### :Microsoft~xcel spreadsheet. The band'Nldth for each absorbance maximum capable of being resolved was measured. The band'Nldth was expressed in nanometers (nm). 

### The calculations were performed using a 

### Microsoft® Excel spreadsheet and 

### Perkin Elmer

### UV WinLab® software.



### Page IO of

### I7 

# !07 L8329-SUV 

# )

# (

(

( Protocol and Standard OperatingProcedureDeviations Therewerenoprotocol orstandard operatingproceduredeviations noted for the study.
Data Storage and Record Retention All original protocols, raw data, and reports will be stored for at least ten years by the Chemicals Quality Services Division, Building 320 ofthe Eastman Kodak Co., Kodak Park, Rochester, New York 14652-6276.

Absorbance Max. (run)



### 190

Absorbance Max. (run) 

### 201

Absorbance Max. 

### (nm) 215 RESULTS NeutralWater MolarAbsorption Coefficient (Umole·cm) 1.63·104


### AcidicWater MolarAbsorption Coefficient (Umole·cm)

9.32·103


### BasicWater MolarAbsorption Coefficient (Umole·cm)

2.11·103 

### nd

## =not determined, absorbancepeakwasnotresolved

Page 11 of 17 

# /Of{ Bandwidth 

### (nm)

nd

Bandwidth (run) 13.79

Bandwidth (run) 

### 9.32

L8329-SUV

### pH ofTestSolutions Solution Identification pH 

### Test Substance Stock 10.06 Neutral

### Test Solution 7.70 Acidic

### Test Solution 1.06 Basic

### Test Solution 13.44 Water 5.99
CALCULATIONS Equation for Converting mg!L to mole/L: concentration (mole/L) = [x](rng/L) x 

### (1g 

### I I000mg) 

### IMW Where; 

### [x] =concentration ofthe test 

### substance solution, (mg!L) (MW) =test substance molecularweight= 442.0g 

### Imole. Equation for MolarAbsorption Coefficient: MolarAbsorption Coefficient =_A_ cxd Where;A =Absorbance at amaximum wavelength c =Concentration ofthe test 

### substance solution (moleiL) d =Pathlengthofthe spectrophotometercell 

### (I em) Equation for Band-width: Bandwidth

## =right 

### side (nm)

- left side (nm) Where;right 

### side (run)=the wavelength at 1/2 the absorbance maxima on the right 

### side ofthe peak left side (nm) =the wavelength at 1/2 the absorbance maximaon the left side ofthe peak Representative Calculations: The test substance calculations represent the acidic water sample at 20I nm. 

### Concentration (mole/L): 32.4 mg/L x 

### Ig/I000 mg 

### I (442.0g 

### I 

### I mole)= 7.33 x 

### I

# o·5

### moleJL

Page 12 of 17 

# /09 L8329-SUV

# (

(

( 

### MolarAbsorption Coefficient: 0.68344 = 

### 9.32

## x I<Y Umo}excm



### ___ 7
___**3_3_x_l_o~-s-m_o_l_dL** 

### ____ __ Bandvvidth: 211.47 nm - 197.68 run = 

### 13.79 nm 

### DISCUSSION Prior to each analysis a background correction was performed with a "blank solution" of the appropriate test substance diluting solvent Figure 1 (page 14 of 17) shows the ultraviolet'visible light spectrum for the test substance 

### in neutral water. The ultraviolet/visible light spectrum for the test substance in acidic water is shown 

### in Figure2 (page 15 of 17). Figure 3 (page 16 of 17) shows the ultravioletlvisible light spectrum for the test substance 

### in the basic water. Using these spectra 

### with the absorbance maxima information, the respective bandwidths and molar absorption coefficients were calculated. The test substance 

### in all three matrices exhibited similar spectra. The test substance clid not exhibit an absorbance above 300 run 

### in any of the three matrices. The ultravioletlvisible light spectrum ofthe test substance 

### in the neutral matrix 

### bad a peak maximum at approximately 190 run. The ultraviolet/visible light spectrum ofthe test substance 

### in the acidic matrix bad a peak maximum at approximately 200 run. Theultraviolet/visible light spectrum ofthe test substance 

### in the basic matrix bad apeak maximum at approximately 215 nm. All test substance solutions were clear and colorless.


### CONCLUSION The results ofthe ultravioletlvisible light spectra indicate that the test substanoe may be susceptible to photochemical degradation.


### REFERENCES 1. Organization for Economic Cooperation and Development (OECD)1981. "Ultraviolet/Visible light Spectroscopy'' (I

### 01). OECD Guidelines for Testing ofChemicals.

Page 13 of 17 

# /JO L8329-SUV

### FIGURE 1 '\ 

### Test Substance in NeutralWater )
0 

## ,g

0>

0 II) <X)

0 0 <X)

# r~ I I 10**~o i~"-** 

0 II) <.0

,0 :--0 I <.0 lo '- \l) E

<r>c 

### :_g ' ll) I I 

### :

. 0 -ll) 'v
'o '-o

v

. 0 L.n 

## ,..., 

# Ls ,..., 

# 10

I

### r~ I I I Lo

0 m 0 <.0 \l) v 

### ..., N 0 ,..... 0 0 0 0 0 0 0 0 c? <( 

## ) Page 14 ofl7 

# /II L8329-SUV

# (

(

( FIGURE2 Test Substance in 

### Acidic Water

0

## ,~ I

# I~

'o Lo ' .... I

10 >-0

<D

0 c-o ' 1()

'O LQ ,"¢ I 

### I 

# 10 

# rg

# -~- lq**r----r----.---~--~~~~~~-r~--.---~----~~** = o r-.**~** 1() • n N o**o~ ~**  0 0 0 0 0 0 0 0 0 < E c:



### Page 15 ofl7 

# 1/:J. L8329-SUV0 0 0'> ci 

### FIGURE3

TestSubstance in 

### Basic Water

co ci /

--- ·0 :-o ' 00 

### I

0 -o

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0**~o** 

### .,.,

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### ------**_-_-_-_-=._-::_-~-=~~--0** ID ci 

### ----------===o 0'> '<r M N 0 0 0 0 ci ci ci ci 9 < E c::



### Page 16 of17 

# /13 L8329-SlN )

)

### F1GURE4 

# (_ Holmium Oxide- (SRM. 2034)



### -----



# (

-

----- ---



## ( Page 17 of 17 

## - I I 0

0 0 1'-

0 I() 10

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### L8329-SUVI 

### \' 

### Final Report 

# CONFIDENTIAL

ANALYSIS BYINFRARED SPECTROSCOPY

Author Christine

### M. Hoffinan

PERFORNITNGLABORATORY Environmental Analytical Services Chemicals Quality ServicesDivision 

### Manufacturing Quality Assurance Organization Eastman Kodak Company Rochester, 

### New York 14652-6276 

### USA

STUDYSPONSOR Eastman Kodak Company Rochester, 

### NY 14652-6267 

### USA ReportNumber. L&329-SIR

STIJDY CO:MPLETION DATE 

# J**~A;ItlY** 

# 7/' ,/ / 

# /IS

# CONFIDENTIAL

ANALYTICAL QUALITY ASSURANCE INSPECTION STATEMENT (CFR 58.35(B) (7) 792.35(B} (7) 160.35(B} (7)) STUDY: STUDY DIRECTOR: HOFFMAN,C ANALYTICAL DIRECTOR: KAN : CQS JOB NUMBER: STUDY TYPE: INFRARED SPECTROSCOPY 

## O'fa.di.f 

# ·Yllc(cftLJv (AUDITOR, QUALITY ASSURANCE UNIT)

THE FOLLOWING PHASES OF THIS STUDY WERE INSPECTED BY ONE OR MORE PERSONS OF THE QUALITY ASSURANCE UNIT ON THE DATES LISTED BELOW.**~TTEN** STATUS REPORTS WERE SUBMITTED TO THE STUDY DIRECTOR AND APPROPRIATE MANAGEMENT. INSPECT

DATES 06/18/98
07/09/98 REQUEST NUMBER PHASE {S) INSPECTED PROTOCOL SUBMISSION CRI,IR TEST REPORT INSPECTION CRI,IR



### Page2 of 12 

# lifo STATUS REPORT DATES 06/18/98
07/09/98



### L8329-SIR

# ( GOOD LABORATORY PRACTICE COMPLIANCE STATEMENT
The studywas conducted according to: United States Food and DrugAdministration, Good Laboratory Practice for Nonclinical Laboratory Studies, 21 CFRPart 58; United States Environmental ProtectionAgency, Toxic Substances Control Act, Good LaboratoryPractice Standards, 40 CFR Part 792; Annex 2, Organization for Economic Cooperation and Development, Guidelines for Testing ofChemicals [C(81)30(Fina1)].

### ~tine M. Hoffman StudyDirector

Page 3

### of12 

# /17 ay/Year

L8329-SIR

### SIGNATURE PAGE



### )

feM.Byme 

# U SponsorRepresentative Page 4 of12 

# //8 L8329-SIR

# ( .TABLE OFCONTENTS
ABSTRACT STUDYAND TEST SUBSTANCE INFORMATION PAGE TestingFacility Sponsor SponsorRepresentative StudyDates Project Participants Test Substance Characterization Test Substance Storage 

### PURPOSE MATERIALS AND 1\IETHODS Instrument Conditions Sample Preparation Protocol and Standard Operating ProcedureDeviations Data Storage and Record Retention 

### RESULTS Page 

### 6 7 7 

### 7 7 

### 7 7 7 7 

### 8 8 8 8 8 

### 8 9 

### DISCUSSION 9 CONCLUSIONS 9 REFERENCES 10 FIGURE I FITRSPECTRUM OFTEST SUBSTANCE 11 

### FIGURE II FTIRSPECTRUJ\-'1 OFTEST SUBSTANCE WITH PEAKFREQUENCIES 

### 12

Page 5

### of 12 

# /19 L8329-SIR

# CONFIDENTIAL

ABSTRACT 

### A Fourier transform infrared (FTIR) 

### spectrum was obtained 

### in conformance with standard operating procedure CQS/EAS/NCS-QOD-0121-0l. A 

### mixture of the test substance in dried potassium bromide (KBr) was scanned from 4000-400 cm· 1 

### using a Perkin Elmer (PE) 1725 X FTIR spectrophotometer. The spectrum ofthe test substance was determined to be consistent with the proposed structureby assigning the major functional groups.

Page 6of12

## /~D L8329-SIR 

# )

# ( 

# CONFIDENTIAL
STUDYAND TEST SUBSTANCE INFORMATION PAGE TestingFacility Environmental Analytical Services Chemicals Quality Services Division Manufacturing QualityAssurance Organization Eastman Kodak Company Rochester, NewYork 14652-6276 

### USA Sponsor Eastman Kodak Company Rochester,NewYork 14652-6267 

### USA SponsorRepresentative Julie M. Byrne Study Dates Study Start Date: Experiment Start Date: Experiment Completion Date: June 16, 1998 June 16, 1998 June 18, 1998 ProjectParticipants StudyDirector: StudyAnalyst: Report Author: Christine M. Hoffman Christine M. Hoffinan Christine M. Hoffman Test Substance Characterization**~** 

### Test SubstanceName: KAN: HAELNumber: SampleRef. Number.: CAS RegistryNumber: 

### CIN: Date SampleReceived: May 27, 

### lY98 Test Substance Storage The sample was stored in a locked cabinet at room temperaturepriorto analysis.

Page 7 of12

## /~} L8329-SIR

### PURPOSE The purpose ofthis experiment was to determine ifthe 

### FTIR spectrum ofthe test substance was consistent with the kno\VTl structure ofthe test substance. This was done by assigning the infrared absorption bands ofthe spectrum to majorfunctional groups and comparing the as,:ignrnents to the proposed structure ofthe test substance.


### MATERIALSAND l'riETHODS Instrument Conditions A FTIR spectrum ofthe test substance was collected using the following instrument conditions: Instrument: Detector: ScanRange: Resolution: Number ofScans: Sampling Technique: Perkin Elmer (PE) 1725 X FTIR Spectrophotometer Fast Recovery Deuterated Tri-Giycine Sulfate (FR-DTGS) 4000-400 em·' 4.0cm·' 16 

### Transmission (KBrpellet) A background spectrum of dried 

### KBr in pellet form was obtained prior to acquiring the test substance spectrum. Sample Preparation A mixture ofthe test substance in dried KBr was prepared such that the intensity ofat least one peak in the spectrum covered 25% ofthe transmittance scale without any peak actually reaching 0% transmittance. The mixture was analyzed using transmission FTIR spectroscopy by means ofa KBrpellet. Protocol and Standard Operating Procedure Deviations There were no deviations from theprotocol orstandard operating procedures. DataStorage and Record Retention All original raw data will be retained for a minimum oftenyears 

### in the Chemicals Quality Services Division archives oftheEastman Kodak Co., Building 320, Kodak Park.

Page 8 of 12 L8329-SIR

## ( RESULTS 

# CONFIDENTIAL

A FTIR spectrum was obtained and the spectral band assignments are as follows:



### DISCUSSION Infrared vibrations 

### in complex molecules couple and mix 

### strongly with 

### one another, therefore, some spectral bandsremain unassigned. The spectralband assignments were consistentwith 

### the known structure ofthe test substance. See pages 11 

### and 12 

### for FTIR 

### spectra ofthe test substance.


### CONCLUSION The spectralband assignments were consistent with theknown structureofthe test substance.

Page 9 of 12 L8329-SIR

### REFERENCES The followingreferences were used as spectral interpretation aids: 

### TheAldrichLibrary Of InfraredSpectra, EditionIII; Pouchert, Charles, Ed. 1981 Silverstein,Bassler, andMorrill 

### SpectrometricIdentification of Organic Compounds, Fifth Edition; JohnWiley and Sons, 1981 LJ. Bellamy

### TheInfraredSpectra ofComplexMolecules, Vol. I, Chapman and Hall; Third**Editio~** 

### 1975.

Page 

### 10 of 12 L8329-SIR

# CONFlD ENTIAL

# CONFIDENTIAL

## .. 

# CONFIDENTIAL

FINALREPORT

ANALYSIS 

### BY NMR SPECTROSCOPY
AUTHOR Christine M. Hoffman
TESTING FACILITY Environmental Analytical Services Chemicals 

### Quality ServicesDivision Manufacturing Quality Assurance Organization EastmanKodak Company Rochester, New York 14652-6276 USA
STUDY SPONSOR EastmanKodak Company Report Number: L8329-N11R STIJDY COMPLETIONDATE



# /J7ANALYTICAL QUALITY ASSURANCE INSPECTION STATEMENT (CFR 58.35(8) (7) 792.35(8) (7) 160.35(8) (7)) STUDY:
_____ STUDY DIRECTOR: STAUDENMi\YER, K**ANALYTI~** DIRECTOR: KAN : CQS JOB NUMBER: STUDY TYPE: NMR SPECTROSCOPY (AUDITOR, QUALITY ASSURANCE UNIT)

TifE FOLLOWING PijASES OF THIS STUDY WERE INSPECTED BY ONE OR MORE PERSONS OF THE QUALITY ASSURANCE UNIT ON THE DATES LISTED BELOW. WRITTEN STATUS REPORTS WERE SUBMITTED TO THE STUDY DIRECTOR AND APPROPRIAT!: MANAGEMENT.
INSPECT REQUEST PHASE (S) STATUS REPORT

DATES NUMBER INSPECTED DATES



### ------- 

## ------- 

# --------- ----------- 06/03/98 PROTOCOL SUBMISSION 06/03/98 CRI,NMR 07/23/98 TEST REPORT INSPECTION 07/23/98 CRI,NMR



### Page 2 of14 L8329-N?vfR 

## )

### GOOD LABORATORY PRACTICE COMPLIANCE STATEMENT
This study was conducted accordingto: Uruted States Food and DrugAdministration, Good Laboratory Practice for Nonclinical Laboratory Studies, 21 CFR Part 58; Uruted States Environmental Protection Agency, Toxic Substances Control Act, Good Laboratory Practice Standards, 40 CFRPart 792; Annex 2, Orgarlization for Economic Cooperation and Development, Guidelines for Testing of Cherrlicals [C(81)30(Final)].

Kathy Staudenmayer Study Director 

# Cl.J,: 

# m**~ ~e**  Sponsor Representative Page 3 of 14 

# M 2Y,/99S Month!Day/Year

L8329-NI\1R

# 1~9

### SIGNATIJRE PAGE

# ~ 2.<-t, 

# /198 Month!Day/Year Study Director



### Page 4 

### of 14 

# /30 L8329-NMR

### TABLE OF CONTENTS

ABSTRACT STUDY Al'ID TEST SUBSTANCE**II~rORMATION** 

### Testing Facility Sponsor SponsorRepresentative Study Dates Project Participants Test Substance Characterization 

### PURPOSE MATERIALS AND METHODS Test Solution Preparation and Test Conditions Protocol and Standard OperatingProcedureDeviations Data Storage and Record Retention 

### RESULTS DISCUSSION CONCLUSION REFERENCES

'H Spectrum 

### FIGURES Figure I Figure II Figure 

### ill Figure IV 1

### H Spectrum with Assignments 'H- 1

### H 2-D COSY Spectrum 'H-'H 2-D COSY Spectrum with Assignments

Page 5 of 14 

# /31 PageNumber 

### 6 7 7 7 

### 7 7 7 8 

### 8 

### 8 8 

### 8 9 9 

### 9

10



### 11 

### 12 13 14

L8329-NMR

# CONFIDENTIAL

ANALYSIS BYNMRSPECTROSCOPY

ABSTRACT Nuclear magnetic.resonance (NrvfR) 

### spectroscopy was utilized to determine the structure of the. test substance. The test substance was dissolved 

### in deuterated chloroform (CDCl3) 

### with trifluoracetic anhydride (TFA) and a one dimensional (1-D) 

### proton 

### CH) N1vfR spectrum and a two dimensional (2-D) 1

### H - 1

### H Correlation (COSY) spectrum were acquired 

### using a Varian Gemini 300

### MHz N1vfR. spectrometer. The acquired spectra were consistent with 

### the known structure for the test substance. Interpretation ofthe acquired spectra was made by 

### assigning the resonance frequencies.

Page 6 of 14 

# J3a L8329-NMR 

# )

)

### STUDY AND TEST SUBSTANCE INFORMATION TestingFacility Synthetic Chemicals Analytical Services Chemicals Quality ServicesDivision Manufacturing Quality Assurance Organization Eastman Kodak Company Rochester,New York 14652 USA Sponsor Eastman Kodak Company Sponsor Representative Julie 

### M. Byrne Eastman Kodak Company Rochester, NY 14652-6267 USA StudyDates Study Start Date: June 7, 

### 1998 Experimental Start Date: June 10, 1998 Experimental Completion Date: June 10, 1998 Project Participants Study Director: Principal Investigator(s): Report Author: Kathy Staudenmayer William 

### L. Lewis Kathy Staudenmayer ChristineM. Hoffman

Page 7 of 14 

# /33 L8329-NMR

# CONFIDENTIAL

TestSubstance Characterization



## ,

Received mto LabOratory: May27, 1998
PURPOSE Molecular structure information of a chemical substance can be useful 

### in predicting and/or understanding its health and environmental properties. 

### N1viR Spectroscopy is widely held as an · appropriate analytical methodology for the determination of structural information. One dimensional and two dimensional 1

### H spectra were acquired for the purpose of elucidating the molecular structure ofthe test substance.
MATERIALS AND METHODS TestSolution Preparation andTest Conditions Approximately 50 milligrams ofthe test substance was dissolved 

### in one milliliter ofCDCl3 

### with 

### TFA. The solution was transferred to a 5-rnm NMR tube and placed 

### in the magnet ofa Varian Gemini high-field 

### NMR spectrometer operating at a 

### proton observation frequency of 

### 300.06 "MHz. The proton

### Nrv1R spectrawere acquired at a temperature of

### 30.0 oc and referenced to tetramethylsilane (TMS) at zero ppm. Protocol and Standard Operating Procedure Deviations None.

Page 8of 14 L8329-NMR

v 

# 86

# . 

# CONFIDENTIAL

Data Storage and Record Retention All original protocols, raw data, 

### and reports will 

### be retained for a minimum often years 

### in the Chemicals Quality 

### Services Division archives 

### ofthe Eastman Kodak Co., Building 320, Kodak Park.
RESULTS Approximate Chemical Assignment• Shift (ppm) 

# :;

- 

# -

- 

### .., I i 

### *See F1gure II for spectral assignments.
DISCUSSION The acquired 1-D and 2-D 1

### H 

### Ntv1R spectra are consistent with 

### the known molecular structure for the substance. The assignments of 1

### H resonance frequencies 

### in the 1-D NMR spectrum shown

# m Figure II were made on the basis oftheoretical cherrilcal shifts and scalar (J) 

### coupling networks obtained through the acquisition and subsequent interpretation of the 2-D COSY experiment shown 

### illFiguresIII and IV. See Figure II for the chemical structure.
CONCLUSION The 

### 1-D and 2-D 1

### H spectra are consistent with 

### the structure ofthe test substance. See Figure II for the chemical structure ofthe test substance.

Page 9 of 14 

# !3f) L8329-N1vfR

### REFERENCES**~** 

### Silverstein, Bassler, andMorrill, 

### SpectrometricIdentification of Organic Compounds, Fourth Edition; JohnWiley and**So~** 

### 1981 

### The SadtlerHandbook of ProtonNMR Spectra, EditorWilliam W. Simons, SadtlerResearch Libraries, 1978 

### R.J. Abraham, 

### J. Fisher, and 

### P. Loftus,

### Introduction toNMRSpectroscopy, John Wiley and Sons, 1988

Page 10 of 14 L8329-NMR

# CONFIDENTIAL

131

# CONFIDENTIAL

138

# CONFIDENTIAL

/39

# CONFIDENTIAL

JlJD

# roNFlOENTIAl

FINAL REPORT TS-98-009 Page 1 of9

## HAELNo.~**KANIH&SNo.(-~** CIN t > 

## ......-----... RANNo.( ' 

# ---- PHYSICO-CHEMICAL PROPERTIES WITH RESPECT TO SOLID FLAMMABILITY
GUIDELINE Annex To CommissionDirective 92/69/EEC Of31 July 1992, Part A: Methods for the Determination ofPhysico-Chemical Properties AUTHOR Tracy W. Panczyszyn TESTING FACILITY Technical Safety Laboratory Health and Environment Laboratories Eastman Kodak etmpany Rochester, New York 14652-6270 USA LABORATORY PROJECT ID HAEL Laboratory Number,,: :) STUDY SPONSOR Eastman Kodak Company STUDYCOMPLETION DATE September 11, 

### 1998 

# !'/I

# fONFIDENTIAL

QUALITY ASSURANCE INSPECTION STATEMENT 

### TS-98-009 Page 2 of9

{21 CFR 58.35(B) {7), 40 CFR 792.35{B) {7), AND 40 CFR 160.35{B) {7)) STUDY: STUDY DIRECTOR: PANCZYSZYN,T.W. PAGE 1 ACCESSION NUMBER: f 09/08/98
STUDY TYPE: SOLID FLAMMABILITY J1/] ·

# /~

# L/l v,,,J (AUDITOR,**QUAL~Y** ASSURANCE UNIT) DATE
THIS STUDY WAS INSPECTED BY 1 OR MORE PERSONS OF THE QUALITY ASSURANCE UNIT. WRITTEN STATUS REPORTS**~ERE** SUBMITTED ON THE FOLLOWING DATES. INSPECTION DATES PHASE(S) INSPECTED 07/09/98 PROTOCOL SUBMISSION 07/27/98 TEST SUBSTANCE DISTRIBUTION RECORDS FILL MOLD AND IGNITE 09/08/98 FINAL REPORT REVIEW STATUS REPORT DATES

09/08/98
09/08/98

### TS-98-009 Page 3 of9 GOOD LABORATORY PRACTICE COMPLIANCE STATEMENT
This study was conducted according to: United States Food and Drug Administration, Good Laboratory Practice for Nonclinical Laboratory Studies, 21 CFRPart 58; United States Environmental Protection Agency, Toxic Substances Control Act, Good Laboratory Practice Standards, 40 CFRPart 792; Annex 2, Organisation for Economic Cooperation and Development, Guidelines for Testing ofChemicals [C(81)30(Final)].

Month/Day/Year



# !43

### REPORT SIGNATURE PAGE TS-98-009 Page 4 of9



### PHYSICO-CHEMICALPROPERTIESWITHRESPECTSOLID FLAMMABILITY

### Mo~th/Day/Year Tracy W.

### ~fnczyszyn,**B.S~ ~**  Study Director 

## /! /


### Glenn T. Bodman, B.S. Month/Day/Year UnitDirector, Technical Safety Laboratory



# 144

### TABLE OF CONTENTS 

### TS-98-009 Page 5 of9 Page Number ABSTRACT 6 Testing Facility 7 Project Participants 7 Sponsor 7 Test Substance Characterization 7 Study Dates 7 Purity Analysis, Structure Confirmation, and Stability Determination 7 Moisture Content 7 PURPOSE 7 FLAMMABILITY (SOLIDS) 8 Materials And Methods 8 Results 8 Discussion 8 DATASTORAGE 9 CONCLUSION 9



# ;16

### HAELNo.' TS-98-009 Page 6 of9
ABSTRACT 

# fONFIDENTIAL

KANNo. )



# --------

---- CIN(._ ) RAN No.(



# --- PHYSICO-CHEMICALPROPERTIESWITHRESPECTSOLID FLAMMABILITY METHODS: EEC Annex to Commission Directive 92/69 EEC of31 July 1992 PartA: Methods for the Determination ofPhysico-Chemical Properties: A.l0. Flammability (Solids) RESULTS:

Flanunability (Solids): Not Highly Flammable

### TS-98-009 Page 7 of9 STUDY AND TEST SUBSTANCE INFO'RMATION

### T~sting Facility 

### Technical Safety Laboratory Health and Environment Laboratories Eastman Kodak Company 

# fONFIDENTIAL
Rochester, NewYork 14652-6270 USA Project Participants 

### Study Director Study Technician(s) Laboratory Director Report Author
Eastman Kodak Company Tracy W. Panczyszyn Elizabeth F. Brandt Glenn T. 

### Bodman Elizabeth F. Brandt Sponsor
Test Substance Characterization 

### Test Substance Name: HAELNo.: KAN/H&S No.: CIN: SRID orLotNo.: Physical State and Appearance: Received at Testing Facility: Laboratory Project ID: Study Initiation Date Experimental Start Date Experimental Termination Date white solid June I, 1998 

### (_ 

# ) Study Dates 

### July 8, 1998 July 27, 1998 July 27, 1998 PurityAnalysis, Structure Confirmation, and Stability Determination 

### Referto composition information contained 

### in notification. Moisture Content 

### Referto composition informationcontained 

### in notification. PURPOSE 

### Thepurpose ofthis study was to evaluatethephysico-chemical properties ofthe test substance with respect to solid flammability. 

# ;17

### ExperimentalDesign FLAMMABILITY (SOLIDS) MaterialsAnd Methods TS-98-009 Page 8 of9

This study was conducted by methods comparabletoEEC Annexto Commission Directive 92/69 EEC of31 July 1992 PartA: Methods for the Determination ofPhysico-Chemical Properties: A.IO. Flammability (Solids). The as received test substance was made into a train of250-mm in length and an attemptwas made to ignite one end ofthe train with a gas flame as apreliminary screeningtest. Accordingtothe Directive: 1) ifinthe preliminary screening test combustion by burning or smoldering occurred over a 200-mm length ofthe train within four minutes, then a detailed burningrate testwould be carried out, or 2) ifinthe preliminary screening test the test substance did not ignite within two minutes, or ignited but failed to propagate combustion either by burning with flame orsmoldering along the 200-mm powdertrain within four minutes, then the test substance would be categorized as not highly flammable and no further testing would be done. The burning rate test wasnot carried out. 

### TestSubstancePreparation The substance was tested as received. 

### Calculations and StatisticalProcedures Not applicable. 

### Protocol and Standard OperatingProcedureDeviations None. 

### Results Laboratory Relative Humidity: 52.1 % OBSERVATIONS: PreliminaryScreening Test: Ignition occurred after 32 seconds and propagated 28 mm down the train before extinguishing. Combustion did not propagate 200-mm. 

### Discussion The test substance was not found to be highly flammable.

### DATA STORAGE TS-98-009 Page 9 of9

The final report, data sheets, all rawdata and an aliquot ofthe test substance have been stored in the testing facility archive managed underGLP-mandated conditions.
CONCLUSION Flammability (Solids): Not Highly Flammable

### COMMERCIAL-IN-CONFIDENCJ;__ 

# c**~'** RISK ASSESSMENT OF

# ~~~~~~~f~~NF~I~NTI~L For Annex VIIC Notification

## HAELNo.~

CAS Registry

## Number:~
CONTRIBUTORS

Julie M. Byrne Willem D. Faber, Ph.D., DABT Ruth Hosenfeld Linda S. Hickey Charles J. Ruffing, Ph.D.

PLEASE DIRECT ANY QUESTIONS TO: Julie M. Byrne Health and Environment Laboratories Eastman Kodak Company



### 1100 Ridgeway Avenue Rochester, NewYork 

### 14652-6267 U.S.A.

SPONSOR Kodak Limited Headstone Drive Harrow, Middlesex HA1 

### 4TY, UK
30 September 1998 

# /So

### COMMERCIAL-IN-CONFIDENCE 

# CONFIDENTIAl TABLE OF CONTENTS

EXECUTIVE SUMMARY RISK ASSESSMENT 1.0 INTRODUCTION 2.0 HEALTH ASSESSMENT- TOXICITY 2.1 HAZARD IDENTIFICATION 2.1.1 Toxicity Data from Animal Studies 2.1.1.1 Acute Toxicity 2.1.1.2 Irritation and Sensitization 2.1.2 Mutagenicity 2.1.3 Carcinogenicity 2.1.4 Reproductive Toxicity 2.1.5 Repeated Dose Toxicity 2.1.6 Toxicity Data from Human Studies 2.2 DOSE-RESPONSE ASSESSMENT 2.3 EXPOSURE ASSESSMENT 2.3.1 Introduction 2.3.2 Occupational Exposure 2.3.3 Consumer Exposure 2.3.4 Public Exposure 2.4 RISK CHARACTERIZATION 2.4.1 Classification Review 2.5 INTEGRATION 3.0 HEALTH ASSESSMENT- PHYSICOCHEMICAL PROPERTIES 3.1 HAZARD IDENTIFICATION 3.2 EXPOSURE ASSESSMENT 3.2.1 Flammability (solids) 3.2.2 Stability as measured by DSC 3.3 RISK CHARACTERIZATION 3.4 INTEGRATION

-i- 

# !51 

# (-==**~**

iii 1 1 1

3

# CONFIDENTIAl

4.0 ENVIRONMENTAL ASSESSMENT 4.1 HAZARD IDENTIFICATION 4.1.1 Toxicity Data 4.2 DOSE-RESPONSE ASSESSMENT 4.3 EXPOSURE ASSESSMENT 4.4 RISK CHARACTERIZATION 4.5 INTEGRATION 5.0 OVERALL INTEGRATION OF CONCLUSIONS

ATTACHMENT Differential Calorimetry Scan

-ii

### COMMERCIAL-IN-CONFIDENCE 

# cc=**-~** 4

5

NUMBER 1

# CONFIDENTIAL COMMERCIAL-IN-CONFinFNr.F

# (~ EXECUTIVE SUMMARY This assessf!Jent of the potential risk to man and the environment for }Nas conducted in -:-;-:---,---------::::---:- support of the submitter's new chemical notification as specified in the Seventh Amendment, Articles 1(1 c), 3 and 7 (92/32/EEC, 30 April1992) to Council Directive 67/548/EEC (27 June 1967). It was carried out in accordance with the principles set out in the European Commission Directive 93/67/EEC (20 July 1993) for substances notified in accordance with Council Directive 67/548/EEC (27 June 1967).

• This substance will not be manufactured or processed in the European Union (EU). The substance will be imported as a component of mixtures. The mixtures are ; used in a commercial The mixtures will contain 0.1-8.0% of the substance in water.
• The mixtures will be imported in 500 ml quantities packaged in plastic bottles. The bottles of will be packaged in cardboard boxes which will also contain an empty
_ and siphon. The user of the will load the into the using the siphon.
• The acute oral LD5o is >2000 mg/kg.
• Based on a review of the health, physicochemical, and environmental assessments, the conclusion at Article 3(4)(i) shall apply: "The substance is of no immediate concern and need not be**consi~red** again until further information is made available in accordance with Article 7(2), 8(3), 8(4) or 14(1) of Directive 67/548/EEC."

-iii- 

# /()..3

### COMMERCIAL-IN-CONFIDENCE RISK ASSESSMENT 

## (__ 

# __ _
1.0 INTRODUCTION 

# CONFIDENTIAL

This assessment of the potential risk to man and the environment for (_ )/vas conducted in

support of the submitter's new chemical notification as specified in the Seventh Amendment, Articles 1(1 c), 3 and 7 (92/32/EEC, 30 April 1992) to Council Directive 67/548/EEC (27 June 1967). The regulations stipulate that the memberstate Competent Authority carry out a risk assessment for new substances. Manufacturers and importers are free to conduct the assessment and include it with the submission of the notification and are encouraged to do so using the principles for assessment of risks to man and the environment specified in Commission Directive 93/67/EEC (20 July 1993) for substances notified in accordance with Council Directive 67/548/EEC (27 June 1967). It is recognized that the basis for this risk assessment and the recommendations provided by the submitter are subject to the scrutiny of the Competent Authority to whom the notification is submitted. The format of the following assessment is outlined in the Commission Directive 93/67/EEC, (20 July 1993) with greater detail provided in guidelines entitled "Risk Assessment for New Notified Substances and Risk Assessment for Existing Substances" issued by the European Commission (DG XI), lspra, Italy, 19th April, 1996. This substance will not be manufactured or processed in the European Union (EU). It will be imported as a component in**mixtur~.** The mixtures will contain 0.1-8.0% of the substance in water. The mixtures will be imported in 500 ml quantities packaged in plastic bottles. The bottles will be packaged in cardboard boxes which will also contain an empty siphon and The mixtures will be used in a commercial The expected to be used in commercial applications. No consumer or general public usage is expected. is

Since this substance will be imported as a component of mixtures, no release to the environment during manufacture will take place. No release to the environment is expected during normal use or processing.

-1-

### COMMERCIAL-IN-CONFIDENCE 

## (_-

- 

### )

2.0 HEALTH ASSESSMENT- TOXICITY
2.1 HAZARD IDENTIFICATION 

# fONFIDENTIAL

2.1 .1 Toxicity Data from Animal Studies:

2.1.1.1 Acute Toxicity: Acute OralToxicity: The oral LDsovalue for male and female rats is greater than 2000 mg/kg. Acute Dermal Toxicity: Test not conducted. 2.1.1.2 Irritation and Sensitization: Acute Derma/Irritation: Test not conducted. Acute Eve Irritation: Test not conducted. Skin Sensitization (Buehler Test): Test not conducted. 2.1.2 Mutagenicity: Salmonella tVPhimurium -Escherichia colt. Test not conducted. Chinese Hamster Ovarv (CHO) Cell ChromosomalAberration: Test not conducted. 2.1.3 Carcinogenicity: No bioassay studies have been conducted. 2.1.4 Reproductive Toxicity: No reproductive toxicity studies have been conducted. 2.1.5 Repeated Dose Toxicity: No repeated dose toxicity studies have been conducted. 2.1.6 Toxicity Data from Human Studies: No data are available from human studies. 2.2 DOSE-RESPONSE ASSESSMENT No hazard was identified and therefore no dose response assessment is necessary. 2.3 EXPOSURE ASSESSMENT

2.3.1 Introduction: There are no data available on human exposure to the substance. The substance is in the mixture at ranges between 0.1 and 8%. -2- 

# }562.3.2
2.3.3

2.3.4

# fONFIDENTJAL Occupational Exposure: 

### COMMERCIAL-IN-CONFIDENCE

# ~ No occupational exposure is expected to the substance. Consumer Exposure: Since it is assumed that these inks are not expected to be present in devices available for consumer use, no exposure to consumers is expected. Therefore, no further assessment was conducted. Public Exposure: No exposure to the public is expected. Therefore, no further assessment was conducted. 2.4 RISK CHARACTERIZATION

2.4.1 Classification Review: The guidelines for determining whether classification is needed appear in Council Directive 92/32/EEC Annex 2 (General Classification and Labeling Requirements for Dangerous Substances). The LDso value for male and female rats is greater than 2000 mg/kg. No classifiable effect as identified in 92/32/EEC (ANNEX 2) was observed. 2.5 INTEGRATION No hazard has been identified in the health assessment of this substance. The substance will be imported as a component of mixtures (inks). No public orconsumer exposure to the substance is expected from the use of these inks. Therefore the conclusion,at Article 3(4)(i) shall apply: "The substance is of no immediate concern and need not be considered again until further information is made available in accordance with Article 7(2), 8(3), 8(4) or 14(1) of Directive 67/548/EEC."
3.0 HEALTH ASSESSMENT- PHYSICOCHEMICAL PROPERTIES
3.1 HAZARD IDENTIFICATION 3.1.1 Flammability (Solids): Not highly flammable Other available data: Stability (Thermal Stability as Measured by Differential Scanning Calorimetry (DSC) under Nitrogen): Exotherm of 49 J/g with an onset temperature of 346°C (See Attachment 1 ).

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### 3.2 

### COMMERCIAL-IN?""NEIDENCE 

## ( 

# ______ ) EXPOSURE ASSESSMENT 

# CONFIDENTIAL 3.2.1 Flammability (Solids) Not applicable, since this physicochemical hazard identification study did not result in classification of the substance. 3.2.2 Stability as Measured by DSC: The substance is not classifiable based on the test result, since there are no criteria for classifying substances as dangerous based on this test. However, the physicochemical properties identified should pose no significant exposure potential in transportation, storage, handling, product manufacturing, or customer use based on the stability as measured by DSC. 

### 3.3 RISK CHARACTERIZATION The required hazard identification study has been conducted and the result has not led to the classification of the substance. In accordance with Article 4(2)(i) of Commission Directive 93/67/EEC, if the substance is not classified by any of the required tests, then a risk characterization is not necessary and the conclusion at Article 3(4)(i) shall apply: "The substance is of no immediate concern and need not be considered again until further information is made available in accordance with Article 7(2), 8(3), 8(4) or 14(1) of Directive 67/548/EEC. 

### 3.4 INTEGRATION No significant risk has been identi.Ued in the physicochemical properties assessment of this substance. Therefore, the conclusion at Article 3(4)(i) shall apply: "The substance is of no immediate concern and need not be considered again until further information is made available in accordance with Article 7(2), 8(3), 8(4) or 14(1) of Directive 67/548/EEC."
4.0 ENVIRONMENTAL ASSESSMENT
4.1 HAZARD IDENTIFICATION 4.1 .1 Toxicity Data: Environmental effects or fate testing is not required at this level of notification. 

### 4.2 DOSE-RESPONSE ASSESSMENT Since no ecotoxicological tests are required to support a VIIC notification, a quantitative dose-response assessment is not applicable.

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# CONFIDENTIAL COMMERCIAL-IN-CONFIDENCE 

# L

____ _**4~** EXPOSUREASSESSMENT This substance will not be manufactured or processed in the EU. Up to 100 kg of the substance will be imported into the European Union. During the intended use of the substance, there will be no release to the environment. Very small amounts of the substance will remain in bottles after use. These bottles are expected to be disposed of at landfills. 4.4 RISK CHARACTERIZATION Although a quantitative PEC/PNEC ratio cannot be calculated from the data available atthis time, the potential for adverse effects is very low based on import volume and anticipated use. Based on the available test data and information, the conclusion from Commission Directive 93/67/EEC, Article 3 (4) (i) shall apply, "The substance is of no immediate concern and need not be considered again until further information is available in accordance with Article 7(2), 8(3), 8(4) or 14(1) of Directive 67/548/EEC." 4.5 INTEGRATION Not applicable at this level.
5.0 OVERALL INTEGRATION OF CONCLUSIONS The Health, Environmental and Physical/Chemical Property Assessments suggest low risk from the use ofthis substance. The assessments suggest that the following conclusion from Article 3(4)(i) of Commission Directive 93/67/EEC (20 July 1993) shall apply: "The substance is of no immediate concern and need not be considered again until further information is available in accordance with Article 7,(2), 8(3), 8(4) or 14(1) of Directive 67/548/EEC."

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### COMMERCIAL-IN-CONFIDENCE

Health and Environment Laboratories Eastman Kodak Company 1100 Ridgeway Avenue Rochester, New York 14652-6267 U.S.A.
APPROVAL PREPARED BY:



### Group Leader, Research and Development Support Group

Julie Byrne/Ruth Hosenfeld 30 September 1998 

### al & 

### Regulatory Information

-6- 

# /b9

# fONHDENTIAl**:s~ ~--er.** **/~9r** Date

. l

# s-~i:1D' Date

# ~or+ 

# 9P DateSample:Size:1.0700mgMethod:25-420GCSEAL10C/MINN2-3:E........:r0r-1IJ......._+J3210-1()I-2-393.27°C60.30J/g99.04°CResidue:BLACK-4'-.40--i'fO,.160.ApprovedBy:-.)...-('cc.·,./_i_!'iTested8y :££02Kh.a2uy.2.1.l:LI_11DSC200240Tempera-ture'TSLFILEIDFile:C:E981279.001Operator:P.KINGSLEYRunDate:6-Jul-9816:30280(oc)MeltcExo346C373.62°C370.15°C48.47J/gRate=0.·56W/gA*E=27.16dT/dt=40.05C/Min320360400440TSL/SC/328OSC-AutoV1.0ETAInst2200::tg-.....